This issue occurs when an investor’s DCS status is changed (opt-out or opt-in), but the investor still receives proceeds or does not receive proceeds after a trade has been executed.
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It happens because:
- the DCS status was modified after the trade date,
- or the opt-in/opt-out was processed after end of trade reports are shared on T+0.
Step-by-Step Resolution
1. Brokers are advised to validate the investor’s DCS status at least 48 hours before trade execution, in line with SEC DCS operational guidance.
2. Trades executed before a DCS status change will settle based on the DCS status at the time of trade execution.
3. Subsequent trades executed after the DCS status change will settle according to the updated DCS configuration (either to the investor’s bank account or the broker’s settlement account).
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Please always confirm an investor’s DCS status before executing trades to avoid settlement discrepancies.
Expected Resolution Timeline
Within 24 hours of receiving a complete complaint.