Instant replay: Recording of the Central Securities Depository Regulation (CSDR) and Pivot webinar on 2/2/22

LAURA CODE: Great. You should have heard a message there saying that we are officially in recording now. So moving along-- for the introductions portion, which I will be happy to kick off, my name is Laura Code. I'm new to US Bank. However, I spent the last 16 years at Brown Brothers Harriman in multiple offices around the globe. 
I'm based in Boston, and I'm part of the global custody services organization. My responsibilities include client engagement and product strategy for global custody. And I'll hand it over in order of our speakers. Next up is Jeremiah Becker. Jeremiah, you're on mute. 

JEREMIAH BECKER: Wonderful technology. My apologies, everyone. Jeremy Becker, manage our global client services team within our global custody operations group. I've been with US Bank for 11 years in different roles all within global custody operations, and have been working on the CSDR project for, oh, as long as anyone would want to. So I appreciate that and I'll turn it over to Elisa Kudrna. 

ELISA KUDRNA: Hi, Elisa Kudrna. I'm a senior digital product owner for Pivot, our online experience for investment services. I've been with the bank for about 14 years in various roles supporting trust and custody. 
So I've had the pleasure to partner with Laura and Jeremiah to bring the transparency and the requirements for CSDR to Pivot that we'll be demonstrating today. 

LAURA CODE: Excellent. Thank you both for the intros. Moving along next to a couple of housekeeping items. So we have an hour together today, and we're planning about 40 to 45 minutes of content before we tackle questions. We will take the questions at the end of the session. And we will be recording the session. 
So let's quickly go over-- hopefully this isn't new for everyone as far as how to ask a question through the Webex events module. Some of you have already submitted questions through the invitation, so thank you for that. If you happen to have a question that comes up during one of the speakers' sessions, you can use the module at the bottom right hand corner of your screen. 
You should see the little Q&A text box. You'll click on that, enter your question in as free text, and then click Send. And that will come through to us. And again, we'll be collecting those throughout the session and then we will announce when we're heading over to questions. 
And last week's session was very interactive. We had quite a few questions at the end. So we're hoping for the same engagement today. 
OK, so let's just move along here to our agenda next before we dive into content. So we're planning to cover, in the order of appearance here, our integrated client communication campaign on CSDR, just to refresh everybody on some of the efforts that have been ongoing, to ensure that everyone has been made aware of the resources and knows how to access those accordingly. 
I'll then hand it over to Jeremiah, who will do a quick refresh on the regulation, which went live yesterday, and changes to US Bank service offering as well that we want to highlight some of those newer developments. And then lastly, the kind of bulk of the presentation today, will be focused on a live demonstration from Elisa on the pivot changes that were made to that platform in support of CSDR and the reporting. 
So we'll tackle number one here, which is the integrated campaign overview-- just to make sure that we're all on the same page with what resources are available to you and your teams related to CSDR so that your teams are better prepared and ready to implement. So in December of 2021, we actually started to blast out more content leading up to the live date. 
There's a couple of different ways that we did this. And just, again, to reiterate, you may not have received one of the e-blasts, which is on the left hand column, but you might have received an email from your relationship manager. We had a couple of different suggested routes of communication. 
So we did launch what we call our e-blast campaign, which you see on the left here, to certain client and business lines. And we also launched a new website page with all of our resources related to CSDR, including a new frequently asked question module on the website, as well as a PDF of that same content for, again, different ways that some of our relationship managers engage with all of you. So that all was sent out, and packaged, and promoted in December of '21. 
And just a quick look at some of those new frequently asked questions, which were really centered around US Bank service offering-- so less about the regulation itself but more about what's changing within our client service, our operations, our technology in light of the settlement discipline regime, which went live yesterday. So there's interactive module, which you see here on the left, which is available on that web page that we created and was linked through all the emails. 
We also have the same content available in a PDF version. And we continue to take in questions from our clients through our client service team and make updates to this as necessary so that, again, clients have a place to go to get some of those questions answered-- some of the more common questions answered about how things are working in the new environment. And then lastly, we launched a LinkedIn campaign as well so that we were promoting everything in multiple channels. 
So we had the email, we had the RM outreach, and client service outreach. And we also promoted all of that through our LinkedIn channel and through our LinkedIn business users as well. So you might have seen something about the Resource Center, you might have seen something about our securities lending offering in terms of CSDR. And our latest post that went out very recently was around these top three things that asset managers and financial institutions should be thinking about in terms of the live date which was yesterday. 
So I'll hand it over to Jeremiah to talk through the settlement discipline regime, which went live yesterday. And just want to make sure you can see the screen OK. Is anything kind of in the way or everything's looking OK on your side? 

JEREMIAH BECKER: Everything looks great to me. 

LAURA CODE: Perfect. 

JEREMIAH BECKER: A little different cause first time we're having this conversation as we're actually live with this. So hopefully everyone is familiar with the regulation and the impact of it. So I'll go kind of high level for it. 
And the big impact of it is basically any trading activity that's happening in the European markets or EuroClear depository, Clearstream depository, and the markets of the EU outside of the UK crest are impacted by this regulation. So if you're doing any buys versus payment, sells versus payment, deliver frees, free receives-- all of those are impacted by this regulation in that any failing trade will result in a penalty, I should say. 
The penalty is basically kind of like a zero-sum in that the at-fault party will be paying out and the not-at-fault party will be receiving in. And that is passed through by the CSD between the two parties. So to kind of determine that, it might be considered a late matching failing penalty or a settlement fail penalty, and that's just basically to capture who is at fault of that trade failing. There's not two different types of exact penalties or two charges per item. 
So the big thing with that is how do you mitigate your fails? How do you cut down on those and build enhancements and efficiencies to cut down on those? That's the high level of what's all going with those. And then just originally, there was going to be a mandatory buy-in feature of the regulation, which due to industry lobbying was announced back in November that that was going to be delayed. 
We haven't heard anything new on when the buy-in regulation will be implemented. It will be implemented at some point. We don't know if that's going to be months or years. But I did understand that they can't actually make the determination until the regulation kind of goes into effect, which was yesterday. So hopefully in the coming months, we'll get more of an understanding of the buy-in portion and everything that would be involved with that. 
There will be a lot more communication similar to this and the communication strategy that Laura referenced as well once we get into the guidance, because that will be a big change as well in requirements of the regulation to be aware of and stay in tune with. So we can go to the next slide, Laura. 

LAURA CODE: Yep. 

JEREMIAH BECKER: Thank you. So what are we doing to kind of change our service offering to better handle these changes in the market? So what we'll be demonstrating, Elisa will be demonstrating, I won't get [INAUDIBLE] trade, fail, and penalty reporting within Pivot. 
That will be available for everyone and all Pivot users to see and get the needed data that they have. So there's been some updates to screens. And like I said, it will all be demoed very soon. Partial settlements. We have coded every single account that is trading on these markets for partial settlement. 
So in the example, your trade is for 1,000 shares and your counterparty's short, but they have 500 to deliver right now, that will automatically settle and cut the risk exposure in half-- and without any changes. There's no changes of tags on how those are instructed, that's automatically been opted in for all of our accounts. So nothing changed on the client part. 
We are also doing with client services, my team, our client service representatives, which you might be familiar with-- the emails that you get daily on a daily pending-failing trade-- we're looking at those trades that have penalties, also looking at, OK, was this at fault of US Bank? Maybe we made an error. Or is this something that we need to make right by removing that off your account, we will flag that internally and do those reviews ourselves, as well as on top of your clients bring those to attention of your client service representative to raise those as well. 
One thing with it is with disputes. The actual dispute through the CSD is very, very strict standards-- so a new issue in where the issuing company doesn't get the shares to the depository would be something where you could dispute a charge. But most items will not be able to be disputed, but that's where we will be reviewing a fault on US Bank's fault or not. 
And if you have any of that you wish to raise or inquire on, please raise those with your client service representative so we can do a case by case review and also pass along if needed. And then the charges will be charged on a monthly basis. And how the process kind of high level will work is right now, all the charges are accruing for February. 
Any failing trades will be accrued. We're getting those in communicating those back on the daily accruals. The actual charge will be charged in the middle of March. We'll be receiving that from our custodian network, which originates at the CSDs. And those charges, then we're going to do another reconciliation and review before we pass those along to a client. 
And those can either be done through, right now it's either based on your business line, who it is-- it would be a direct debit posting or on the invoice posting in April. Once we get those, reconcile those, pass those along, and then the billing area will get those in April and post early to mid-April to make those postings to your account. 
Very soon, we're working hard with MT537 penalty messages [INAUDIBLE] messages on sending those outbound. Right now, everything is in Pivot for reporting. And we're working diligently to try to get the swift messages turned on for any of our clients that elect to receive those. If you do want to receive those, please reach out to your client service, we just need the VIC to send the message to and your account number that you would like to receive it so that we can have everything coded for those so that as soon as they are live, that everyone who wants one is receiving those. 
Another area we're hoping to have within the coming late this quarter, early second quarter is moving into global custody model of ALERT-- so then having all ALERT users without having any manual work basically will flow directly as we update our settlement instructions in our system, they will all flow right down to all of their clients that want that without any emails or interactions as we currently do. 
So that would be coming up very soon. And then also the ability to support client's relationships if they're using any third party fintechs or technology providers. The most notable one we've heard about is Access Fintech from our clients. We're working on having those feeds that we're the closest on. And having a direct feed from of our data provided to Access Fintech so that you're able to view all your data if you're using Access Fintech. 
Same with the penalty messages. If you are going to be signing up with Access Fintech or if you're looking into them, please reach out to your client service representative. And if you can provide the account numbers that you're looking to enroll for those, then we can make sure that gets on our proper tracking so that once you are fully live with Access Fintech, that is all passing along as well, or any other third party provider that you may be working with. 

LAURA CODE: Excellent. Thanks, Jeremiah. 

JEREMIAH BECKER: Oh yeah. Got to now turn it over to Elisa. 

LAURA CODE: I think we're good for Elisa, so I'm just going to give her the control. 

ELISA KUDRNA: All right. Let me start sharing my screen here. All right, are you able to see Pivot? 

LAURA CODE: Yes. 

ELISA KUDRNA: Perfect. All right, so Pivot is our simple, fast, secure way for you to log in and access your information. So this is our online experience to help create efficiencies in your everyday tasks so you can make the strategic and operational decisions. So as a part of this initiative, what we've brought to Pivot is the transparency into your trades, and the failed status, and amounts that CSDR has introduced. 
Today, I'll go through our notifications process, the online views, and reports that can be ran. This feature is delivered into our global custody experience. So your default sight, if you use the ITC portal, or the court muni, or fund services site, those will still be your main default site, but you'll be able to toggle over to Global Custody. And the emails that we provide, we'll provide that deep link. 
So I will go into that in detail here. So the first piece I want to start out with is our notifications process. As a part of this process, all global custody pivot users will be set up to receive email alerts for any non-US unaffirmed trades-- so those trades that are at risk of failing-- any non-US failed trades that are now at risk of a penalty, and then there's an alert for US trades with penalties. 
Notices will be sent daily until the trade has been settled or canceled. And you'll receive a single email notifying you of the activity with multiple trades so you don't get bombarded with a lot of, if you had 100 trades placed that day, you're not going to get 100 emails. And again, this alert allows you to deep link into our global custody site where that information resides. 
A user can also opt out of the email alerts, and I'll demonstrate that today. So the deep link here will take you to Pivot, in which you will log in. And it'll bring you into the global custody site. 
In here, you can look at the trade activity from the home page here. By clicking on the trade activity, you can see the recent activity for today plus three business days and that status. So in this example here, I do have a pending trade with a penalty here-- so we've got some stage data. So it did not settle. 
By clicking on the status, you can see the detail of that trade, including what is the penalty amount, the currency, the reason it's not settled. This information flows through from our swift messaging, the MT548, for those of you that are familiar with that, and we pass that information on to you. 
And there's the additional detail related to the trade, including the broker, the clearing market, et cetera. So these email alerts will allow you to see the information for unmatched that's at risk of failing, the failed activities that's at risk of penalty, and also those items with the penalty. We also not only have the email notifications, but we also have the online notifications. 
By navigating to the home page to notifications, if you did receive an email that stated there were multiple activity, you can go into this notifications link and drill down into those specific requests. As I mentioned, you also have the ability to opt in or opt out of notifications. By clicking on the Edit Notifications, you can enter in your security question and update your notification preferences. You can do it at the specific account or based on all accounts. 
And in here, you can determine what you would like to see on the online and/or the email view. All accounts as you are provisioned will automatically be opted in into these CSDR-related alerts, which is the non-US trades failed, the non-US trades penalized, and the non-US trades unmatched. But you do have that ability to update your preference. 
So we have a couple of different areas also where you can drill down into this information. What I've showed you here first is from the home page just a quick view. If you would like to drill down further, [INAUDIBLE] the information or look at information in a more aggregate view, you can go into the portfolio view. And within the portfolio view, you can select one account or many accounts. 
And within the trades, you can customize the data points that you would like to see and the order of those data points. So in this example here, I have that penalty Information-- penalty currency. The reason I can go in and edit, and add, and remove columns as I see fit. 
All this information is exportable. So anywhere where you see on the bottom toolkit here that Excel document, you can export the information for further use. And here, you can sort for historical information, search by trade date, settlement date, or transaction date. So we allow the flexibility for you to drill down into what you would like to see. 
Another view we have of this information is in the transactions trading. In this online view, again, we allow some additional flexibility here. And you can look by statuses or by currency. So if you quickly want to see anything in a failed status in a non-US currency, you can apply these filters again to get that same information, but different ways to drill down into that. 
And again, by clicking on the status, you can see that detail, which is exportable. But those [INAUDIBLE] online views on how you can get to the information. The next area I would like to highlight are the reports. We added two new reports out in our reporting module. 
So by going to report reporting, you can run our great penalty report, which will provide you any of the non-US traits that have a penalty for a specific date range. We also have an unmatched failed trade report that runs for the current day anything that's currently in that failed status or unmatched status. 
You can run these reports on-demand by clicking Run a Report and Trades and then selecting these two new reports, the trade penalty or the unmatched and failed, and running the report on-demand. Or we have the ability where you can customize and schedule these reports. 
So by clicking on the blue link here to customize and schedule, you can select those same reports. And here, I'm going to run the [INAUDIBLE] I set up a failed trade report. By selecting traits and selecting the trade penalty report, I'm going to select all of my accounts. And I am going to schedule this to run daily. 
What this means, instead of going out and pulling it on-demand this report will be generated daily for my review out in the file cabinet. I do have the ability to customize this report. So what are the fields that are important to me? 
There's only five data points I want to see-- the account, the penalty, and the amount. I can do that and customize the order and the data. And then I can schedule and/or share this. So in this example, I'm going to call it the penalty report. 
And I am going to schedule and distribute this. What this allows me to do is, again, come in and see this report daily, weekly, monthly-- whatever the frequency I prefer. And I can send it just to me or I can send it to other users within my organization. 
So these other users will see this information at the same time that I do and don't have to go through all the steps to recreate it. So I went ahead and set up that daily report. Once the daily report has been completed, I can wait for it to run daily, or I can also go in in that custom layout that I prevented, I can always go in and run it on-demand. 
So I'm going to ahead and run this and show you an example of the layout. So what this will do, I can select my date range. So if I want to look at anything with a penalty to date, I can put in that range. If you're looking to reconcile in a future month for the activity that happened in February, you can put in that date range to reconcile. 
I'll go ahead and run the report. And once it's available, it will go into your downloads for you to view. This is an example of that penalty report based on the fields that I provided. That same process works for the unmatched and failed report. 
It'll give you today what is the activity that you have in your account that is unmatched or in a failed status so you can actively monitor those at-risk items for a penalty. Just a couple of other clerical things-- what I've highlighted there today is how you can get the online notifications, how you'll have the online notifications, how once you have those notifications you can drill in on the online views, and how you can run reports, how you can schedule and share those, or run the reports on-demand. 
Just a couple other clerical things-- as I mentioned in the beginning, that you can toggle to the site. So this brought us right into Global Custody. If you want to go back to your preferred site, if you have access to ITC Portal or Court Muni, you can come in to your welcome menu and toggle over to the other site. 
If you would prefer to change your default site, we do have options in My Profile where you can change your preferred site. So I'm set up for the global site that has access to all this CSDR information. So you can update that based on your preference. 
And another way to navigate into your online and email preferences is through the welcome menu notifications. And just another area to get to that same screen if you want to opt in or opt out of various online notifications. All right, so with that being said, that is what I wanted to cover today, Laura. I think we can open it up for Q&A. 

LAURA CODE: Great. And just one additional point, Melissa, on your demonstration regarding the client portal, the legacy portals, let's say, and global just to ensure that everyone's aware that everything Elisa is showing today as far as pivot reporting for CSDR is through global. So as Elisa just outlined, kind of the way to toggle between, I just, again, wanted to mention it because it was a question that came up in our last session as well-- just to make sure that's clear. 

ELISA KUDRNA: Thank you. 

LAURA CODE: Excellent. So moving over to questions, we're going to tackle, again, we want to encourage folks to use the module if you haven't already. But we're going to start, to give you some time to put in your questions if you haven't already, with the questions that were submitted through the invitation process last night. 
So we will just kind of trickle through those. And then as other questions are coming through live, we'll toggle back and forth. So our first question from the invitation process was around fees, Jeremiah. So I will be directing this one to you. What fees will be charged and who will be responsible for those payments if the trades fail? 

JEREMIAH BECKER: Yep. Hopefully I alluded to this earlier, but the fees will be charged on any failing trade. And it's the at-fault party. So a counterparty short shares, whoever shorts shares is the at-fault party. So that would be a settlement fail penalty. 
Whereas opposed to another one [INAUDIBLE] late matching penalty could be settlement date. A client fails to send in a trade ticket until the day after settlement date and it immediately matches and settles. Well, that's going to be a late matching failing penalty, because the trade wasn't instructed and the market looks at who was second to market to get in for those type of penalties. 
So even though your instructions may have been perfect, you're still going to be charged penalty because you were second in. So the best thing we can do is just instruct on trade date, get a full matching cycle to have your trades reviewed to resolve any potential issues to clear those, because basically, that's the type of logic for whatever it may be. 
If it's counterparty missing, one of the two parties has to amend. So whoever was wrong in that will be charged the penalty. And you could go on, and on, and on with all the different scenarios that are there. But that's kind of it in a nutshell for your trades. 

LAURA CODE: Yep. And as far as what fees, Jeremiah, we've been directing folks to online resources for that. If you'd like to see a breakdown or a table, we've seen a lot of news covering that lately. So that is available online as well if you want to see the breakdown. 

JEREMIAH BECKER: Yep. And we'll have the reporting that Elisa alluded to where you can pull a report for [INAUDIBLE] in March, look at all your February penalties, it will pull all your trades that have a penalty, and they will all be listed there so you can sum it up and get an expectation of what you're going to be having to pay or receive, because you can receive it if you're doing everything right. 

LAURA CODE: Exactly. You might see a credit in your account. OK, so next question is about Euro Clear. How does Euro Clear work? What are the processes that make this different than settling domestically? Is it easier to settle foreign trades this way with US Bank? 
And before I hand that one over to Jeremiah, I just wanted to clarify and just reiterate that Euro Clear is in scope for CSDR, meaning failing trades that settle at Euro Clear are under the settlement discipline regime. So there are some clients in books of business that are really heavy on Euro Clear activity, so just wanted to make sure that folks are aware of that. And I'll hand it over to Jeremiah around specifically the question about whether it's different than settling domestically. 
Obviously you wouldn't be having fees if you were settling with DTC, or the penalties, I should say. And the question around, is it easier to settle foreign trades this way with US Bank, Jeremiah. 

JEREMIAH BECKER: I wouldn't say necessarily easy. Every market's got its little nuance. But Euro Clear, it's a depository that's mainly there for euro bond settlement. It does also allow government bonds from around the globe or other type of fixed income. There are some equities settlement there as well. 
And it's just kind of due to that large, vast, everything that can settle kind of across borders. It's used a lot. However, you do sometimes get degradation in the asset servicing that Euro Clear provides as opposed to holding your assets in a local market-- say, Germany, for example, versus holding in Euro Clear. So really, there's no real difference from our perspective, it's just another depository in scope for the regulation. 
There's a lot of eurobond activity. Like I said, that's the main asset that's traded there which are all priced in US dollars. So that's why it's very attractive for US investors to be able to settle there. 

LAURA CODE: Excellent. Thank you. OK, moving along, we had a question around a little bit of the same regarding whether US investors trading on US exchanges have any exposure to the new failed trade regime. So only if those trades settle at an ICSD would be the answer to that one, right, Jeremiah? 

JEREMIAH BECKER: Yep, correct. Just one little nuance to that-- in your example for US investors in the US, it shouldn't be in scope. But there are some cases where the underlying security-- so I know in our book of business across all of our accounts, we have four Mexican positions that are held currently in Mexico, but they're actually domiciled in a European-based market. 
So those actually, even though they're settling in Mexico, the Mexican depository has accounts in the local market to settle those. So those are actually in scope of the regulation. And we've reached out to those clients too. And that just kind of makes it easier basically kind of proposed to them, hey, do you want to move these to the local market just to make it a little easier for you? But otherwise, if you have them in Mexico, FYI, you might see this outside of what you might be expecting for a trade in Mexico. 

LAURA CODE: So thank you. So we've had a lot of questions for you, Jeremiah. I'm going to switch over to Elisa for a few. Elisa, a question that came in live which we want to tackle here-- can we set up a notification to alert us an hour, 30 minutes, or two hours before a trade will fail? 

ELISA KUDRNA: Right now, we don't have scheduling for the alerts. I believe the failed trades are triggered at 3:00 PM central and the unmatched at 7:00 AM central. So we do, from the alerts perspective, do some batching. But as far as being able to see that information within Pivot, it's real time-- as in once we get that information stored in our system of record, it's available to view and [INAUDIBLE] 
And we can look into that scheduling feature. It's not available at this time. 

LAURA CODE: OK, excellent. Another one for you. Elisa, around reports. Is there a report that shows if the trades are matched before settlement date so we can act in advance if necessary? 

ELISA KUDRNA: So today, we did focus on the unmatched. So we have the inverse of that. Again, that's something we can explore making sure that data point is on the trade activity screen. But right now, if you're wanting to know what is outstanding, you would use that unmatched report. 

LAURA CODE: Excellent. And last question for you, Elisa, before I hand it back over to Jeremiah for a few. Can we create a report to reflect only the CSDR penalties daily and monthly? 

ELISA KUDRNA: Yes. And you can do that via the scheduling. So just real quick, I'll go back into the report. And when you set up the schedule, you can set that up daily, which is what I had demonstrated. So just going to the schedule here. 
So you can do that daily or we have a monthly, weekly, quarterly option. So we do have that flexibility. And if you want it month end or a specific day of the month, we do allow that flexibility. And then, again, you can always run requests on demand with the customized date range. 

LAURA CODE: Excellent. Jeremiah, question for you around auto partialing. Will US Bank auto partial even if the client is not stating this on the Swift? 

JEREMIAH BECKER: Correct. Yep, what we've done is we've coded it at an account level across the board in the European markets. So any trade that comes in, if it doesn't specify, will be included in an auto partial settlement. If you don't want to partial settle, you submit manual trade tickets. You would need to state on your manual trade ticket submission to not auto partial that so we can send the outbound Swift appropriately. 
Which is if you were a Swift client that sends in, you would want to utilize the NPAR tag-- I believe it's a 23G tag. Don't quote me directly, because I'm going off the top of my head here. But it's the NPAR tag that's a Swift industry standard. That will go into our system, go outbound with that, and that tells the receiving custodian to not allow partial settlement on those if you wanted to opt out. 
However, my thought is if I'm not going to partial settle, I just have a higher risk in the possible chance at a higher penalty fee being accumulated. So if it was me, I would be doing partial settlement across the board. And that's why we're doing it. 

LAURA CODE: Right. Right. And that was also in one of the changes to the service offerings that you would cover, Jeremiah, as far as the blanket approach we're taking at the custodian level and with our sub-custodian network as well. This is probably one of the most popular questions we've seen over the past week, even without this webinar. 
We've seen a lot of questions around what's required of clients with partials, and will they need to send new instructions. So thanks to the folks that put that question in for today as well. OK, I've got another question here around what constitutes a failed trade, Jeremiah. So late matching, lack share chair delivery, et cetera. Any more examples you want to give? 

JEREMIAH BECKER: Yeah, a failed trade is basically considered anything that fails when the market closes on contractual settlement date, also known as intended settlement date. You might see that if you're looking on Google or searching CSDR. So if I book a trade in Germany, it's a t-plus 2. So today's trade date, so settlement date would be Friday the 4th. If that fails in Germany on Friday, that is a failed trade and that will be assessed a penalty. 
LAURA CODE: Excellent. I also wanted to go over the question around the debits and credits in terms of how those are passed to the account. And I know, Jeremiah, you covered our default offering for this process will be to apply those penalties, whether they're debits or credits, to our clients' monthly custody invoice process. And Jeremiah walked through the timing of that. 
I also wanted to call out that we are able to support direct debits to client accounts if that is the preference. So we are going to be offering both at this time. And we are starting to see some clients requesting the direct debit process versus the monthly custody invoice process. Anything else you wanted to add there, Jeremiah? 

JEREMIAH BECKER: Yeah, I'd just add only one-- if you do have a preference, make sure you're reaching out to your account manager on your account as opposed to your client service rep, or just include both for visibility. But that would be handled by your account manager within our business plan that does that set up, who handles your billing. They would make that change. 

LAURA CODE: Yep. OK, I've got some good questions that just came in live to ask more for you, Jeremiah. The first one is, similar to DTC, is the client able to DK a trade back to a broker if they have failed to give the client delivery? 

JEREMIAH BECKER: That's good question. So with international trading, everything has to go through a matching process. Now, for those who might be familiar with share-dumping across certain markets, that's now been removed for European markets as part of this regulation. So everything has to go through a matching process. 
But in the case of, maybe you don't know it, if you're instructing and we have counterparty doesn't recognize counterparty missing as your trade status, basically because the counterparty never actually instructs it or if they're instructing to you, and that trade gets canceled or taken down, there will be no penalty because it wasn't ever matched up and never actually settled or anything, because it would be technically like a late matching failing penalty on the second party to actually instruct. So in those instances, if it's been instructed and you cancel it, then the other party never instructs it because they don't know about it or you don't know about it and they're instructing to you, then there would be no negative impact to you or the counterparty. 

LAURA CODE: Yep, that makes sense. OK, we've got another question here around brokers again. Many times, brokers receive client instructions but fail to send them their delivery instructions. In this case, they may have the trade-out to be matched, but the client is unable to submit because of unknown delivery instructions-- so kind of a similar paradigm to what we just covered. Who would be at fault in this case if the client is unable to submit because of unknown delivery instructions? 

JEREMIAH BECKER: Yep, good question. Let me answer the question first. It would be, unfortunately, you would be at fault, because you would be second to the market provided that goes out matches and settles immediately because the broker had already been instructed in the market. So you'd be charged that penalty. 
And that would be something that you would not be able to dispute through us, US Bank, through the CSD, because they would look at it as two parties, you were second, boom, within the regulation, you're the late matching. However, you could go and claim your broker on the outside of the CSDR processes to recoup those losses because I would assume you have in writing that they didn't give you their SSIs and you need to get those so you could say we receive this penalty in this fee so we're claiming those. Please give us that money back. 

LAURA CODE: Excellent. OK, we had more of a Webex question around how can we rewatch the recorded session. We will be able to send the link out. We'll figure out a way either to post it to our Resource Center online, or we'll be able to send through a thank you email with the link. So you can look out for that in a couple of different ways. 
OK, looks like we have covered all of the pre-submitted questions as well as the lives. So last call for live questions if you want to ask any of our experts anything on your mind one day into CSDR live date. Otherwise, we can adjourn. 
And thanks, Elisa, for bringing up the web page. So that is where we'll look to post the link and also send out a confirm with the link as well to our attendees. OK, it looks like we're still at our same number of questions here in the module. 
So we'll look to adjourn. And just want to thank all of our speakers for their expertise and participation. And thank you to all of our attendees who had submitted questions ahead of time and live in the session. Definitely helps keep the engagement up and also we'll look to incorporate some of these into our standard materials as well. Thanks, everybody. 

ELISA KUDRNA: Thank you. 

JEREMIAH BECKER: Thank you. Thank you, Laura. Thank you, Elisa.