g service providers (CMSPs). As proposed, a CMSP would be required to create, implement, maintain and enforce policies and procedures that “facilitate straight-through processing and describe in an annual report its current procedures, progress, and the steps it intends to take to facilitate straight-through processing of institutional trades.” The SEC remarked that the shortening of the settlement cycle could lead to a rise in the use of CMSPs, and explained its belief that proposed Rule 17Ad-27 would assist with the efficacy of trade processing.The SEC intends to make CMSPs’ annual reports publicly available on EDGAR, to enable the public to review and analyze progress on achieving straight-through processing. The annual reports would need to be tagged for XBRL.ConclusionThe proposed amendments are a long-awaited step forward in modernizing settlement cycles to reflect technological advances and address systemic risk.Footnotes1)Shortening the Securities Transaction Settlement Cycle, 87 Fed. Reg. 10436 (Feb. 9, 2022).2) Release No. 34-80295 (Mar. 22, 2017), 82 Fed. Reg. 15564 (Mar. 29, 2017).3)See Deloitte & Touche LLP, Depository Trust and Clearing Corporation, Investment Company Institute, & Securities Industry and Financial Markets Association, Accelerating the U.S. Securities Settlement Cycle to T+14) See Shortening the Securities Transaction Settlement Cycle, supra note 1 at 10454.