Delivery Requirements and the Settlement Cycle

Every step that follows execution is driven by the settlement clock. The clock tells the customer when cash moves, tells the firm when securities must be delivered, and tells the back office when books must close. For Series 6, the governing rule is Securities Exchange Act (SEA) Rule 15c6-1, and the current standard is T+1.

What is the standard settlement cycle under SEA Rule 15c6-1?

SEA Rule 15c6-1 prohibits a broker-dealer (BD) from entering a contract that provides for payment and delivery later than one business day after trade date (T+1), unless the parties expressly agree otherwise at the time of the transaction.

• Effective date: May 28, 2024 (shortened from T+2)
• Trade date (T): the business day the trade is executed
• Settlement date (T+1): the business day after trade date when securities and payment change hands
• Covered transactions: equities, corporate bonds, municipal bonds, Exchange-Traded Funds (ETFs), mutual-fund shares processed via National Securities Clearing Corporation (NSCC) Fund/SERV, and limited partnerships that trade on an exchange
• Excluded from the rule: exempted securities, government securities, municipal securities, commercial paper, bankers' acceptances, and commercial bills

Rule exception: a firm-commitment underwritten registered offering priced after 4:30 PM Eastern Time (ET) settles T+2 unless the parties agree to a longer cycle.

Think of it this way: T+1 means a trade booked Monday settles Tuesday. The settlement date is when securities leave the seller's account and cash leaves the buyer's, even though the legal price was locked in the day before.

Which products settle on a cycle other than T+1?

Different products have different operational conventions, but most now line up at T+1.

Exam Tip: Gotchas

• T+1 became effective May 28, 2024. Any exam item referencing "T+2" as the current cycle is outdated. The shift from T+3 to T+2 was 2017; the shift from T+2 to T+1 was 2024. Most Series 6 products (equities, corporate bonds, municipal bonds, ETFs, mutual funds via Fund/SERV) all settle T+1.
• Municipal securities are technically EXEMPT from Rule 15c6-1, yet the industry adopted T+1 for munis on May 28, 2024 by operational convention. A distractor that says "municipal securities settle T+2 because they are exempt from 15c6-1" tests the candidate on the difference between legal exemption and operational practice.

When must a customer pay for a securities purchase under Regulation T?

The settlement cycle drives a set of downstream deadlines.

• Customer payment deadline: under Regulation T, a customer must pay for a purchase by two business days after the standard settlement date = T+3 in a T+1 world
• Delivery obligation: a selling customer must deliver the security to the BD in good deliverable form by settlement date
• Mutual-fund redemptions: Investment Company Act (ICA) Section 22(e) requires payment of redemption proceeds within 7 calendar days of tender (a ceiling, not a standard); operational practice via Fund/SERV is T+1
• Variable-contract transactions: purchases and exchanges are processed under the carrier's contract. "Settlement" here means the transfer of units into the contract owner's separate-account sub-account, typically at the next-valuation-date Net Asset Value (NAV)

Exam Tip: Gotchas

• The Reg T payment period is T+3 under a T+1 settlement cycle. The payment period equals standard settlement (T+1) plus 2 business days. Before May 2024 it was T+4; the 2024 conversion shortened it by one day.
• ICA Section 22(e)'s 7-day redemption window is a CEILING, not a standard. A fund that settles T+1 via Fund/SERV complies with 22(e) (seven calendar days is the outer limit). A fund that delays beyond seven calendar days without Section 22(e) relief is in violation. A rep should quote operational T+1 to the customer, not the 7-day statutory maximum.