On 11 July 2019, the European Securities and Markets Authority updated its Q&As on the implementation of the Central Securities Depository Regulation (CSDR).

Part IV of the Q&As dealing with internalised settlement now contains answers to the following questions:

  • Should an investment firm report client orders where the corresponding settlement instructions are forwarded in their entirety to a custodian? What if the custodian is established outside the EEA?
  • Should an investment firm that does not hold any client assets and that performs trade netting in order to reduce the amount of settlement instructions be considered as a settlement internaliser in the meaning of the CSDR, and therefore be required to comply with the reporting obligations pursuant to Article 9 of CSDR?