79 Action Items | 9 Workstreams | 8 Segments | 54 Pages
August 2026 edition
A settlement fail is the last state of a chain the firm could see on trade date: an instruction enriched from a stale SSI, a confirmation that missed the gate, a recall issued a morning late, a currency bought for the wrong value date. The penalty arrives a month later against a reference nobody can match, and the board sees one rate that hides the cell where the exposure lives.
The Fails Reduction Program is an implementation checklist for removing those causes. Nine workstreams run from the baseline and the root-cause taxonomy through the SSI golden copy, trade-date matching, inventory and partials, the cash leg and the intraday queue, to the penalty desk and the five-measure board pack. Every item is one verifiable action with the failure mode that makes it worth doing, the artifact that proves it was done and the test that says when, and it names a rule only where the rule sets the test.
Sample Items
03-05 Put every SSI change through an authenticated channel with independent verification of the requester against a contact the firm already held before the request, and log the verifier, the method and the time on the record.
Watch out. A verification call made to the number on the change request verifies the request against itself. Call back on the contact the firm held before the request arrived, and treat a change that coincides with a new contact name as two changes needing two verifications.
05-05 Use the hold and release mechanism as a deliberate control, with a written rule on when an instruction may be sent on hold, who releases it, and by when, and never as a device for matching early while deciding later.
Watch out. Instructions are sent on hold to meet the matching deadline and then forgotten, and PREA (your instruction on hold) is the reason code on a fail that cost the firm a penalty one release would have avoided. Report PREA fails separately each day and name the releaser.
08-03 Lodge every disputed penalty with the CSD or the custodian inside the appeal window (under the ECSDA framework, at any time from the daily report and no later than the 10th penalties business day of the following month), with the evidence the CSD's procedure requires.
Watch out. Where the appeal goes to the custodian, who forwards it to the CSD on its own timetable, the firm's real deadline is the custodian's cutoff and not the CSD's 10th penalties business day. Obtain each custodian's appeal cutoff in writing and key the firm's deadline to the earlier one.
Subscribers to the Journal may download the full checklist, including all 79 items across 9 workstreams, with the Excel working register.
