Investment Advisers and T+1: Rule 204-2 Time Stamps

Updated October 2026, after T+1 took effect. First published March 2024.

The one T+1 rule written for investment advisers is a recordkeeping rule. Since May 28, 2024, Advisers Act Rule 204-2(a)(7)(iii) has required a registered adviser to keep, for any transaction subject to Rule 15c6-2(a), "each confirmation received, and any allocation and each affirmation sent or received, with a date and time stamp for each allocation and affirmation that indicates when the allocation and affirmation was sent or received." The first version of this post was a list of technology projects (cloud, AI, cybersecurity) and never mentioned it. This version covers what the rule asks for and how advisers get trades affirmed on trade date.

Which Trades and Which Records

The rule reaches the trades where a broker-dealer has to work through allocation, confirmation, or affirmation with another party to settle, which in practice means institutional trades. The SEC said in the February 2023 adopting release that some registered advisers won't have any such records because they have no institutional advisory clients.

For the trades it covers, you keep the original of each written confirmation you receive and a copy of each allocation and affirmation, whether you sent it or received it. Allocations and affirmations each need a date and time stamp. Confirmations don't. Electronic records are fine if you meet the conditions in Rule 204-2(g).

Three details from the release matter in practice:

There's no required time stamp format and no common clock. The proposal had said advisers should generally stamp to the nearest minute. The final rule doesn't require it, partly so the SEC wouldn't have to define "end of trade date" or make everyone handle time zones the same way.
You can rely on a third party, such as a custodian or sub-adviser, to make and keep the records. That doesn't reduce your obligation under the rule.
The rule says "sent or received" on purpose. If your custodian affirms and sends you a copy, that copy is your record, and it needs its own time stamp.

The third point matters because custodians do much of this work. The SEC cited DTCC remarks that up to 70% of institutional trades are affirmed by custodians, and the Investment Adviser Association agreed with that figure for its members' trades.

Why the SEC Wanted the Time Stamps

The SEC's reasoning was that allocation timing drives everything after it. The broker can't confirm on time without the allocation, and the affirmation is the adviser's final sign-off on the trade's terms. It said the records would help its staff prepare for adviser exams, help advisers find what delays their allocations and affirmations, and let advisers show they met any contractual deadline or any requirement a broker set under Rule 15c6-2. An examiner who asks why a trade failed can now ask for the time your allocation left the building.

How Advisers Get Trades Affirmed on Trade Date

The deadline that matters in the evening is DTCC's 9:00 p.m. ET affirmation cutoff on trade date. Before T+1, the SEC put same-day affirmation at about 68% of trades. DTCC reported that after the switch nearly 95% of trades were affirmed by the 9:00 p.m. cutoff (its data as of May 2024).

The adviser's part of that comes down to a few habits:

Send allocations as fills come in, not in an end-of-day batch. Every later step waits on them.
Know who affirms each account. If it's the custodian, find out what time it needs your allocation or instruction to make 9:00 p.m.
Ask each broker what its Rule 15c6-2 procedures expect from you. A broker that chose policies and procedures over written agreements has to set target times on trade date, describe how it will deal with an adviser or custodian that's slow to allocate or affirm, and measure and document its affirmation rates. Your timeliness is in those numbers.
Keep your standing settlement instructions current with every broker and custodian, so a matched trade doesn't fail on a stale account number.

Central matching services automate much of the allocation-to-affirmation chain. Our post on allocation, confirmation, and affirmation tools covers what they do. For the broker's side of Rule 15c6-2, see Rule 15c6-2 in practice.

A Test You Can Run This Week

Pick ten institutional trades from last month, including at least two your custodian affirmed and one in a sub-advised account. For each, pull the allocation with the time it went out, the confirmation, and the affirmation with its time. If any piece lives only at the custodian or the sub-adviser, ask how fast they can produce it. Check that every time stamp says which time zone it's in, since the SEC left the format to you.

This post is for informational purposes only and does not constitute legal advice. For guidance on specific regulatory obligations, consult your counsel or compliance advisor.