When one lender sells a slice of a syndicated loan to another, the price is agreed in minutes. Handing over the loan takes weeks: a signed confirmation, an assignment, identity and tax checks by the bank that runs the loan, often the borrower's consent, and a wire. Settlement is the work of moving a traded loan through those steps, and every day it runs past the market's seven-day target has a price.
This guide is for people who settle, fund or oversee secondary loan trades: settlement analysts and trade closers on bank and dealer desks, operations teams at CLO and loan fund managers, middle-office providers, agency bank transfer teams, heads of loan operations, and the controllers who sign off on delayed compensation. No background needed.
Imagine you are a loan settlement analyst at a bank that trades syndicated loans. On Wednesday, September 9, 2026, your desk sold $25,000,000 of the Corvane Packaging Holdings term loan to a CLO, Alderbrook CLO 2024-1, at 99.375 cents on the dollar. Seven business days later, on Friday, September 18, the market's clock ran out and your bank began owing the buyer $2,144 a day. It is now Tuesday, October 13: day 23.
The documents were signed by day 3. The loan's administrator, Brackwell Agency Services, held the trade for four days over the buyer's expired tax form, then sent the borrower a consent request on Wednesday, September 30. Corvane's treasurer never answered. The settlement platform has said "pending borrower consent" for two weeks, and the buyer wrote last week: "We are at T+20."
Settlement platform · this morning
Status
Pending borrower consent
Waiting on
Corvane, since Sep 30
Next step
Wait for a reply
Reply expected
Tue, Oct 27 (desk median)
Credit agreement · §10.06(b)(i)(A), p. 142
Borrower consent
Required for this buyer
Unless
It objects in writing
Within
10 Business Days of notice
Window ends
End of Thu, Oct 15
Wait: settle Oct 27Count: settle Oct 16Columbus Day, Monday, October 12, does not count.
Counted from the notice date, skipping the holiday, the borrower's silence becomes consent at the close of Thursday, October 15. The administrator's daily report shows no objection. Settling on Friday, October 16 (day 26) means 28 calendar days of delayed compensation at $2,144: $60,024. Waiting for a written reply, which on the desk's own record comes a median of eight business days after the window closes, means settling on Tuesday, October 27, after 39 days: $83,605.
Reading the transfer clause and counting business days saves eleven days of compensation, $23,581, on one trade, and gives the buyer a date.
Secondary loan trades from handshake to funding: the documents, the clocks, consent and delayed compensation
How a traded syndicated loan changes hands, who has to act, how long it takes, and what each late day costs, explained without selling anything. If you are new to loan operations, start here.
01 · In plain words
Settling a syndicated loan trade: why a sale agreed in a minute takes weeks to finish
Large companies often borrow from a group of lenders at once. One bank arranges the loan, and dozens of banks, CLOs (collateralized loan obligations, funds that buy loans and issue notes against them) and loan funds each take a share. One bank is named to run the loan for all of them: it keeps the list of who holds how much, collects the interest and passes it on.
The loan is called syndicated, and the shares trade. A holder that wants out sells its piece to another investor, usually through a dealer desk. The bank regulators' Shared National Credit program, which reviews the largest loans shared among banks, counted $6.9 trillion of large shared commitments in its 2025 review.1
The sale itself is quick. Two traders agree a borrower, a loan, an amount and a price on the phone or in a chat, and under New York law the trade binds once those essential terms are agreed.2 Then the slow part starts. The two sides sign a trade confirmation on the industry's standard form, the buyer says which of its funds get how much, and both sign an assignment.
The bank that runs the loan then checks who the new lender is, collects its tax forms and records the transfer. If the credit agreement says so, the borrower must consent too. Only then does the buyer wire the price and become a lender of record.
The industry body for the US loan market, the Loan Syndications and Trading Association (LSTA), sets a target: a performing loan trading at or near its face value (par) should settle seven business days after the trade date, written T+7. A distressed loan, one trading on the separate distressed documents, gets twenty, T+20.3
Those clocks live in the trade documents the two sides sign, so the remedy for missing them is money. From T+7 the buyer is treated as if it already owned the loan. The seller is still the lender of record and still receives the interest, so it passes that interest to the buyer, keeping back a charge for the purchase price it has not yet been paid. That transfer is called delayed compensation.2,4
Most trades miss the target. In July 2021, according to LSTA data the SEC quoted in its December 2022 liquidity proposal, the average par trade took 23 business days and only one in five settled inside T+7.5 Much of the delay sits with firms that are not party to the trade: the bank running the loan, which has its own queue, and the borrower, which may never answer.
Settlement is the work of moving each trade through those hands: knowing what holds it today, who holds it, what the documents allow, and what the wait is costing.
Where settlement sits in a syndicated loan's life
The loan is madeAn arranger syndicates a term loan to banks, CLOs and funds; one bank is named to run it.
A holder sellsA bank desk sells $25 million of it to a CLO at 99.375. Price agreed, trade binding, T+0.
The trade settlesConfirmation, allocation, assignment, identity and tax checks, borrower consent, funding memo, wire. Target T+7; the example took 26 business days.
The new lender is recordedThe bank running the loan enters the buyer in its register; interest now goes to the buyer.
It trades againThe buyer votes on amendments, receives payments and may sell, which starts the cycle over.
Step 3 is the subject of this guide. The people, companies and figures in this example are fictional.
Who sets the clock, who can stall it, and who pays for the wait
No regulator sets T+7
The seven days are a term of the LSTA's standard trade documents, which both sides adopt in the confirmation. The SEC's one-day settlement rule covers securities trades by brokers and dealers; loans settle on their own documents and clocks.6
The firms that set the date never signed the trade
The bank running the loan and the borrower decide when the transfer can happen. Neither is party to the trade or pays delayed compensation, and the borrower may refuse a buyer it dislikes.7
Silence can count as yes
Many credit agreements treat a borrower that does not object within a set number of business days as having consented. One published clause uses five days.8 The count runs from the notice date and skips the holidays in the agreement's own definition of a business day.
A buyer can lose its compensation
Since November 2016 a buyer that has not signed the confirmation and assignment by T+5, or is not ready to pay from T+7, gets no delayed compensation, while a missing borrower or agency-bank consent leaves it intact.2
Settlement vocabulary used throughout this guide
Par and distressed
The two sets of LSTA trade documents. Par (or near par) covers performing loans; distressed covers loans in or near trouble, with more paperwork and a T+20 clock.
Assignment
The transfer that makes the buyer a lender of record, signed by both sides and accepted by the bank running the loan. A participation passes on only the payments, and the seller stays the lender.
Delayed compensation
From T+7, interest on the traded amount less a carrying charge on the purchase price, paid by the seller to a buyer that met its own deadlines.
Deemed consent
A clause that treats the borrower's silence as consent once a stated number of business days has passed after notice.
Par, near par or distressed, and assignment or participation: what a buyer of a syndicated loan receives
In shortTwo choices made at the trade decide how it settles. The documentation, par or distressed, sets the clock, the paperwork and how interest is split. The form, assignment or participation, decides whether the buyer becomes a lender with a vote or only receives the cash flows through the seller.
A syndicated term loan has one credit agreement and many lenders. The agreement names one bank to keep the register of lenders, collect payments and process transfers; its formal title appears in every assignment clause, and this guide calls it the administrator.
In the Shared National Credit program's 2025 review, US banks held 45% of the $6.9 trillion of commitments; the rest sat with foreign banks and nonbank lenders such as CLOs and funds. Nearly half of all commitments were leveraged.1
US banks hold under half of the $6.9 trillion of large shared loan commitments
Shared National Credit commitments, 2025 review, $6.9 trillion
$6.9Tcommitments
US banks45%
Other holders: foreign banks, CLOs, funds, insurers55%
Source1 · The release gives the US banks' share; the other 55% is the remainder.
Show the numbers
Part
Value
US banks
45%
Other holders: foreign banks, CLOs, funds, insurers
55%
Par or distressed: chosen at the trade
The LSTA publishes two families of trade documents. Par (also called par/near par) is used for performing loans that trade close to face value.
Distressed is used when the borrower is in trouble or the loan trades at a deep discount; it adds a purchase and sale agreement with wider representations about the seller's title and the history of the position. The two sides choose the documents when they agree the trade, and the choice sets the settlement clock: the date from which delayed compensation is counted is "generally T+7 for par/near par trades and T+20 for distressed trades."3
Distressed trades also offer three ways to treat interest that accrues while the trade is open: settled without accrued interest, paid on the settlement date, or "trades flat", which "is typically only utilized by market participants when the loan is non-performing" and no interest is being paid.3
Assignment or participation: lender of record, or a share of the cash
Most trades
Assignment
The seller assigns its rights and obligations to the buyer under the assignment and assumption form attached to the credit agreement. When the administrator records it, the buyer is a lender: it receives payments directly and votes on amendments.
The fallback
Participation
The seller stays lender of record and passes the economics to the buyer. Trades on LSTA documents that cannot get consent to an assignment must settle this way, leaving the buyer "with no direct relationship with the borrower and no direct voice."7
Where it is recorded
The register
Ownership of the loan is whatever the administrator's register says. Until the transfer is recorded, the seller is the lender, whatever the trade ticket says.
Because syndicated loans are contracts between lenders and a borrower, they settle outside the clearing houses that move stocks and bonds. In Kirschner v. JPMorgan Chase Bank, the Second Circuit in August 2023 upheld the dismissal of state securities claims because the plaintiff had not plausibly shown the notes in the syndicated term loan at issue to be securities; the court added that a different transaction could be judged differently.9
Electronic settlement platforms (ClearPar and Trade Settlement Inc. are the two named in the 2016 rule change) carry the documents and status between the parties; the transfer still happens in the administrator's register.2
03 · The documents
Confirmation, standard terms, assignment, administrative questionnaire, tax forms and funding memo: the paperwork of one trade
In shortFive documents move a par trade. The confirmation and its standard terms bind the two traders; the assignment and the buyer's questionnaire and tax forms go to the administrator; the funding memo states the money. A distressed trade adds a sixth, the purchase and sale agreement. Each document has a different author and a different signer, which is why a trade touches four firms.
Document
What it does
Who prepares and who signs
Trade confirmation
Records the borrower, facility, amount, price, trade date, par or distressed documentation and any special terms. Incorporates the LSTA Standard Terms and Conditions.
Drafted by one side (or generated by the platform from the trade details); signed by both
Standard Terms and Conditions
The rulebook behind the confirmation: delayed compensation (Section 6), buy-in and sell-out (Section 16), payment timing, the cost of carry.2,4
Published by the LSTA; adopted by reference
Assignment and assumption
The legal transfer, on the form attached to the credit agreement, sometimes with extra representations the agreement requires (the platform's "pop-up" questions).2
Seller and buyer sign; the administrator (and the borrower, where required) consents
Administrative questionnaire, KYC and tax forms
Tells the administrator who the new lender is, where to send payments and how to withhold tax: a Form W-9 for a US lender, a W-8BEN-E for a foreign entity such as an offshore CLO.
The buyer, to the administrator
Funding memo
The purchase price calculation: amount × price, accrued interest and fees, delayed compensation, any adjustments.
Seller (or platform); agreed by the buyer before the wire
Purchase and sale agreement
Distressed trades only: representations about title and the chain of prior transfers, indemnities, and how claims and distributions pass.
Seller and buyer
The buyer signs or provides five of the six; the borrower decides only its consent
Who acts on each document of a par trade by assignment
No partReceivesSigns or providesDecides
SellerBuyerAdministratorBorrowerTrade confirmationSigns or providesSigns or providesNo partNo partAllocationsReceivesSigns or providesNo partNo partAssignment and assumptionSigns or providesSigns or providesDecidesReceivesQuestionnaire, KYC, tax formsNo partSigns or providesDecidesNo partBorrower consent requestReceivesReceivesSigns or providesDecidesFunding memo and wireSigns or providesSigns or providesReceivesNo part
Our reading of the sources2,3 · Borrower: consent is needed only where the credit agreement requires it for this buyer.
Show the numbers
Seller
Buyer
Administrator
Borrower
Trade confirmation
Signs or provides
Signs or provides
No part
No part
Allocations
Receives
Signs or provides
No part
No part
Assignment and assumption
Signs or provides
Signs or provides
Decides
Receives
Questionnaire, KYC, tax forms
No part
Signs or provides
Decides
No part
Borrower consent request
Receives
Receives
Signs or provides
Decides
Funding memo and wire
Signs or provides
Signs or provides
Receives
No part
Tax forms expire on a fixed date
The administrator will not record a lender it cannot pay. A foreign buyer's Form W-8BEN-E "will remain valid … for a period starting on the date the form is signed and ending on the last day of the third succeeding calendar year, unless a change in circumstances makes any information on the form incorrect."10 A form signed in any month of 2022 lapsed on December 31, 2025.
A CLO manager running dozens of vehicles therefore has a predictable wave of expiring forms every January, and a trade that reaches the administrator with an expired form stops until a new one arrives.
Every document has a different owner. The trader owns the confirmation, the closer owns signatures, the buyer's operations team owns allocations and tax forms, the administrator owns the questionnaire review and the register, and the borrower's treasurer owns consent. A settlement analyst owns none of them and chases all of them.
04 · The rules and their dates
From the 2016 reform to the 2026 late payment fee: the LSTA terms and credit agreement clauses that set settlement rules
Status as of October 2026
In shortSettlement runs on contract. The LSTA's standard terms set the clocks and the money; the credit agreement sets who may buy and who must consent; regulators touch settlement only indirectly, through rules for the funds that hold loans. The terms changed four times in ten years: requirement-based delayed compensation in 2016, cleaner conventions in 2017, a cost of carry based on SOFR (the overnight US dollar rate the New York Fed publishes) in 2021, and a fee for late payment of the price in 2026.
Four changes to the LSTA terms in ten years, with the SEC's fund rules alongside
Sep 1, 2016Delayed comp needs requirements met
No-fault regime replaced; documents due T+6, then T+5 from November 1, 2016.
Nov 18, 2016SEC liquidity rule
Funds must classify loans; long settlement noted.
Jun 9, 2017Conventions revised
Commencement generally T+7 par, T+20 distressed.
Dec 1, 2021SOFR cost of carry
Average daily SOFR plus 11.448 basis points.
Dec 16, 2022SEC proposes ending the less-liquid tier
Would have moved most loans to illiquid; not adopted.
May 28, 2024Securities move to T+1
Syndicated loans keep their own clock.
Jan 12, 2026Late payment fee proposed
Price paid two or more business days late.
May 4, 2026Late payment fee published
Interest for the late days; invoice within 30 days.
T+7 commencement; delayed compensation only if the requirements are met; buy-in and sell-out from T+20.2
In use; amended 2016, 2017, 2021, 2026
LSTA distressed confirmation and purchase and sale agreement
T+20 commencement; settled without accrued interest, paid on settlement date, or flat.3
In use
Requirements-based delayed compensation
Replaced the "no-fault" system, which many argued "actually aggravates the delayed settlement phenomenon."2
Effective September 1, 2016
Cost of carry revision
One SOFR-based rate in place of each credit agreement's own benchmark: average daily simple SOFR plus 11.448 basis points.4
Trades from December 1, 2021
Late payment fee
A payor that remits the price two or more business days after the transfer is effective owes interest for the late days; not an exclusive remedy.13,14
Published May 4, 2026
The credit agreement
Eligible assignees, minimum amounts, borrower and administrator consent, deemed consent, disqualified lenders, the recordation fee, the business day calendar.7,8
One per loan
SEC Rule 22e-4 (2016)
Funds classify each holding by how fast it converts to cash; bank loan participations "have historically entailed settlement periods that are longer" than other markets.11
In force
SEC 2022 liquidity proposal
Would have removed the "less liquid" category most loans sit in. The September 2024 release adopted reporting changes only: "we are not adopting amendments to the underlying rules at this time."5,12
Not adopted; absent from the June 2025 withdrawal list15
Why the 2016 reform mattered
Before September 2016, delayed compensation accrued to a buyer from T+7 "under most circumstances regardless of whether a loan trade has actually closed." Critics said that guarantee removed the buyer's reason to hurry, and let dealers in the middle wait for the end buyer at no cost.
The LSTA replaced it with a requirements-based standard "in the expectation that it will induce parties to reduce settlement times."2 The same alert reported the starting point: in the second quarter of 2016, "only 23 percent of par trades in the U.S. loan market settled within seven business days."2
Why the 2026 fee exists
The newest change targets the last step. Lawyers summarizing the proposal wrote that payors were increasingly missing the payment deadline, usually by "only one or two days," and that settlement risks and costs "have risen to previously unseen levels."13 The published version lets the payee charge the loan's all-in rate on a performing loan, or the cost of carry rate on a non-performing, distressed, payoff or proceeds trade, for the late days, invoiced within 30 calendar days.14 It changes nothing about consents or the administrator's queue.
05 · The clocks
T+1, T+5, T+7 and T+20: the business-day deadlines inside a par trade and a distressed trade
In short"T+" counts business days after the trade date. On a par trade, trade details go to the platform by T+1, signed documents are due by T+5, delayed compensation starts at T+7, and from T+20 either side can buy in or sell out against a party that will not perform. A distressed trade's compensation clock starts at T+20. Holidays move every date.
A par trade's obligations all fall inside the first week; its costs start after it
Business days after the trade date, par/near par trade settled on a platform
Both desksBuyerClock and remedies
Trade details submitted to the platform
Seller's signature pages, consents pursued
Buyer signs confirmation and assignment
Buyer elects it can settle from T+7
Delayed compensation accrues if requirements met
Buy-in or sell-out available
T+0T+5T+7T+14T+20
Our reading of the sources2,3 · Early-day trades (trade date within six business days of the loan's funding) run from funding: 14 business days instead of T+7.
Show the numbers
Activity
From
To
Trade details submitted to the platform
0
1
Seller's signature pages, consents pursued
1
7
Buyer signs confirmation and assignment
1
5
Buyer elects it can settle from T+7
5
7
Delayed compensation accrues if requirements met
7
21
Buy-in or sell-out available
20
21
Day
What happens
If it is missed
T+1
The party responsible (the dealer if only one side is a dealer, otherwise the seller) submits trade details to the platform; on paper trades the drafting party delivers the confirmation and assignment.2
A seller that misses it gives up delayed compensation; a buyer gets a notice and a second chance to T+5
T+5
The buyer's signed confirmation and assignment are due (T+6 in the September–October 2016 phase-in).2
The buyer loses delayed compensation
T+7
Commencement of the delay period for par trades; the buyer must stand ready to pay from here.2,3
Delayed compensation accrues daily to a buyer that met its requirements
Funding + 14
Early-day trades, struck within six business days of the loan's funding, run from the funding date instead.2,16
Same as T+7
T+20
Par: buy-in and sell-out available against a non-performing party. Distressed: commencement of the delay period.2,3
A cover trade and an indemnity for market losses; not available where the delay is the borrower's or administrator's consent
What counts as a business day
The trade terms' clocks count business days, and a credit agreement usually defines a Business Day as one on which banks in New York are open (the example's agreement does, on the screen in Part B).
In 2026 the Federal Reserve observes Labor Day on Monday, September 7, Columbus Day on Monday, October 12, Veterans Day on Wednesday, November 11, and Thanksgiving on Thursday, November 26.17 A trade struck on Wednesday, October 7, 2026 reaches T+7 on Monday, October 19, one day later than the weekday count suggests, and every later date moves with it.
The two clocks use different units. Deadlines are counted in business days; delayed compensation, once it starts, accrues for every calendar day, because the loan earns interest over the weekend.
06 · Consents
Borrower and agency bank consent: who can refuse a buyer, when silence counts as yes, and how to count the days
In shortMost credit agreements need the administrator's consent to every new lender and the borrower's consent unless the buyer is already a lender, an affiliate of one or an approved fund, or a default is continuing. Borrower consent is usually "not to be unreasonably withheld" and is often deemed given after a set number of business days of silence. Reading the clause and counting the days is where most of the weeks are won or lost.
What a typical assignment clause asks for
Who may buy
Eligible assignees
Most US agreements require buyers to be accredited investors with experience in loans.7 Agreements also bar natural persons, the borrower's own affiliates and names on a disqualified lender list.
How much
Minimums and fees
A minimum assignment ($1,000,000 for the term loan in the example's agreement) and a processing and recordation fee paid to the administrator, unless both the administrator and the borrower agree otherwise.
Who must agree
Consents
The administrator for any buyer that is not already a lender, affiliate or approved fund. The borrower too, "not to be unreasonably withheld", unless a default is continuing.7
When the borrower says no
Consent "is provided to the vast majority of proposed assignments," a 2023 analysis by Crowell & Moring found, but "a substantial number of assignments have failed to garner approval because a borrower—or, by proxy, the borrower's private equity sponsor—has withheld consent to all or certain classes of prospective lenders." Borrowers preparing an amendment or a restructuring prefer buyers they expect to vote with them; sponsor-owned borrowers often reject other sponsors' funds.7
Courts have not yet drawn the line between a reasonable and an unreasonable refusal for syndicated loans; the authors point to case law that consent can be refused only for "a legitimate business reason" exercised in good faith, and that a refused buyer may lack standing to sue, since it is not a party to the agreement.7 A trade on LSTA documents that cannot be assigned then settles by participation.
Counting a deemed consent window
A deemed consent proviso turns silence into consent. One published sample reads: the borrower "shall be deemed to have given its consent five Business Days after the date notice thereof has been delivered" unless it rejects the assignment first.8 Other agreements use ten days or more, and some have none. Three facts decide the date: the length in the agreement, the day the notice was delivered (usually by the administrator), and the agreement's Business Day definition.
A ten-day window is two calendar weeks, or longer with a holiday inside it
Calendar days from notice to the end of a deemed consent window, New York business days
7 days5 business days
14 days10 business days
15 days10 days, Columbus Day inside
Our reading of the sources8,17 · Counted from a notice delivered on a weekday; the window ends at the close of the last business day.
Show the numbers
Window in the agreement
Calendar days
5 business days
7 days
10 business days
14 days
10 days, Columbus Day inside
15 days
Worked count: the example from the top of the page, ten business days.
The notice: the administrator delivered the consent request to the borrower's treasurer on Wednesday, September 30, 2026. The delivery day itself does not count.
Days 1 to 7: Thursday, October 1 to Friday, October 9, skipping the weekend in between.
Monday, October 12 is Columbus Day, a New York bank holiday, so it is not a business day and does not count.
Days 8, 9 and 10: Tuesday, Wednesday and Thursday, October 13 to 15.
The result: absent a written objection, consent is deemed given at the close of Thursday, October 15, and the trade can settle on Friday, October 16.
Waiting for a written answer would have meant waiting on a borrower with no deadline at all.
Two cautions keep the count honest. Silence counts only where the clause says so: an agreement without the proviso needs a written yes. And the notice date has to be proven, which in practice means the administrator's own record of delivery, and the administrator's confirmation that no objection arrived, before the parties schedule settlement.
07 · Delayed compensation
How delayed compensation is calculated: the buyer's interest on the traded amount, the seller's carry on the price, and who forfeits it
In shortFor each calendar day a par trade runs past T+7, the buyer is credited with the interest the loan earns on the traded amount and the seller keeps a carrying charge on the purchase price at average SOFR plus 0.11448%. The net usually runs from seller to buyer. A buyer that missed its own deadlines gets nothing, distressed trades use different conventions, and the price itself must now be paid on time.
What the buyer is credited and what the seller keeps
net per day = amount × loan rate ÷ 360 − purchase price × cost of carry rate ÷ 360
Delayed compensation "is meant to put the parties to a loan trade in the same position they would have been in had the settlement date not been delayed by entitling the buyer to receive the contractual interest accruing under the assigned loan during the period of delay net of a fixed amount that the seller is entitled to retain."2
In plain terms: until settlement, the seller is still the lender of record, so it still receives the loan's interest, and the buyer still holds the cash it will pay. Delayed compensation evens that out in two legs.
The first leg credits the buyer with the interest on the traded amount at the loan's own rate. The second leg lets the seller keep a charge, called carry, on the purchase price it has not yet received, at the cost of carry rate. The first leg minus the second is the day's delayed compensation, usually paid by the seller.
The par terms call the net figure the net credited amount (Sections 6.A and 6.B); Alston & Bird note that a seller paid late could already reclaim it for the delay period, a remedy sellers have rarely used.14 The examples here use a 360-day year; use your facility's own basis.
Where the carry rate comes from
For trades from December 1, 2021, the cost of carry rate is the average of daily simple SOFR from two business days before the delay period starts to two business days before the delayed settlement date (that last day excluded), plus a spread adjustment of 11.448 basis points.4 The spread is the Federal Reserve's tenor adjustment for one-month LIBOR, 0.11448%, written into Regulation ZZ.18
SOFR is the overnight rate the New York Fed publishes "each business day … at approximately 8:00 a.m. ET"; it ran between 3.62% and 3.95% from September 1 to October 29, 2026, so the carry rate on a trade open through that period was roughly 3.7% to 4.1%.19
Step
What you do
With the example's dates
1. Mark the two ends
The delay period starts at T+7; it ends on the delayed settlement date.
Starts Friday, September 18, 2026; settles Friday, October 16
2. Step back two business days from each
These bound the SOFR days that are averaged.
Wednesday, September 16 to Wednesday, October 14, October 14 excluded
3. Average SOFR over that span
Add each day's published SOFR and divide by the number of days.
Say the average comes to 3.85% (illustrative)
4. Add the spread adjustment
Add 0.11448% to the average.
3.85% + 0.11448% = 3.96448%, the carry rate
The rate is final only two business days before settlement, when the averaging span closes. A claim worked out earlier is an estimate.
An illustrative trade, at four prices
Take $10,000,000 of a term loan paying SOFR plus 3.25%, with SOFR at 3.85% (an illustrative level inside the autumn 2026 range). Here is one late day at a price of 100, worked line by line.
Step
Working
Result
1. The loan's rate
SOFR 3.85% + margin 3.25%
7.10% a year
2. First leg: interest on the traded amount, one day
$10,000,000 × 7.10% ÷ 360
$1,972.22
3. The carry rate
3.85% + 0.11448%
3.96448% a year
4. The purchase price
$10,000,000 × 100%
$10,000,000
5. Second leg: carry on the price, one day
$10,000,000 × 3.96448% ÷ 360
$1,101.24
6. Delayed compensation for the day
$1,972.22 − $1,101.24
$870.98, about $871
7. For a trade 14 calendar days late
$870.98 × 14
$12,194
At par, SOFR drops out. The buyer is credited SOFR + 3.25% and the seller keeps SOFR + 0.11448% on the same $10 million, so the net is 3.25% − 0.11448% = 3.13552% a year, and $10,000,000 × 3.13552% ÷ 360 is the same $870.98 a day. Below par the second leg is charged on a smaller sum, so more of the interest reaches the buyer. At 95 the price is $9,500,000, carry is $1,046.18 a day, and the buyer receives $926.
The cheaper the loan, the more each late day costs the seller
Net delayed compensation per calendar day on $10,000,000 at SOFR + 3.25%, SOFR 3.85%
Price 100$871
Price 99.375$878
Price 95$926
Price 85$1,036
Illustrative · replace with your own numbers · Interest on par at 7.10% less carry on the price at 3.96%, 360-day basis. Replace with your loan's rate and the period's average SOFR.
Show the numbers
Purchase price
Per day
Price 100
$871
Price 99.375
$878
Price 95
$926
Price 85
$1,036
The example's sale, day by day
The example uses its own sample rates: the loan pays 7.37% (SOFR plus 3.25% on the period's base) and the desk applies a fixed 4.31% carry rate. The example counts every calendar day from T+7, Friday, September 18, up to the day before settlement.
Step
Working
Result
1. First leg: interest on the traded amount, one day
$25,000,000 × 7.37% ÷ 360
$5,118.06
2. The purchase price
$25,000,000 × 99.375%
$24,843,750
3. Second leg: carry on the price, one day
$24,843,750 × 4.31% ÷ 360
$2,974.33
4. Delayed compensation for the day
$5,118.06 − $2,974.33
$2,143.73, shown as $2,144
5. Owed by today, Tuesday, October 13
25 days, September 18 to October 12 × $2,143.73
$53,593
6. Settling Friday, October 16, on deemed consent
28 days, September 18 to October 15 × $2,143.73
$60,024
7. Settling Tuesday, October 27, after a written reply
39 days, September 18 to October 26 × $2,143.73
$83,605
8. The difference
11 days × $2,143.73
$23,581
Of the $5,118 a day the loan earns, $2,144 goes to the buyer
The example's sale, one calendar day past T+7
Seller keeps as carry on the $24,843,750 pricePaid to the buyer as delayed compensation
Interest on $25,000,000 at 7.37%$2,974$2,144
Fictional example from this guide · The example's carry rate (4.31%) is the sample desk's setting; the LSTA formula would use the period's average SOFR plus 0.11448%.
Show the numbers
Seller keeps as carry on the $24,843,750 price
Paid to the buyer as delayed compensation
Interest on $25,000,000 at 7.37%
$2,974
$2,144
Who loses the right to compensation
A buyer that misses T+5. Unsigned confirmation or assignment, or no election that it can settle from T+7 on a platform, means no delayed compensation.2
A seller that misses T+1. If the seller was responsible for submitting trade details and did not, delayed compensation "will not apply to the transaction."2
Never because of a third party. Delayed compensation "will continue to apply even where necessary consents and approvals to the transfer have not been obtained" from the borrower, the administrator or anyone else.2 The seller bears the cost of a silent borrower.
Distressed trades. The net credited amount is a par/near par remedy and does not apply to distressed trades; on distressed trades interest is handled by the settled-without-accrued-interest, paid-on-settlement-date or flat conventions instead.14,3
New CLOs. A buyer that tells the seller before T+7 that it is a new CLO issuer may set a blackout during which the transfer is not made effective.2
A desk is on both sides of the market, so the same formula pays it on late purchases and costs it on late sales. Each claim belongs to one trade and one counterparty; two desks that trade often may settle a month's claims as one payment, but a dispute is always resolved trade by trade, on start date, rate, carry and day count.
08 · How long trades take
How long US par loan trades take to settle: what the published numbers show from 2016 to 2023
In shortThe LSTA measures settlement times every quarter, but publishes them to members. The figures in the public record say the same thing from 2016 to 2023: roughly one par trade in four or five settles inside T+7, the median ran from about 12 days around 2016 to T+15 in July 2021, the average ran well above it (T+23 that month), and a long tail runs past T+20. Your own desk's median is the number to measure.
Only one par trade in five settled inside T+7 in July 2021
Share of US par loan trades settled within T+7
23%Q2 2016
29%2020 monthly average
20%July 2021
Source2,5 · 2020 is the SEC's July 2021 figure plus the nine points it says the share fell from the previous year's monthly average.
Show the numbers
Period
Settled inside T+7
Q2 2016
23%
2020 monthly average
29%
July 2021
20%
In July 2021 the median trade took twice the standard, and the average three times
Business days from trade date to settlement, US par loan trades
LSTA standard7
Median, July 202115
Middle-office average, buy side (2023 factsheet)16
Average, July 2021 (a seven-year high)23
Middle-office average, sell side (2023 factsheet)23
Source5,20 · July 2021: LSTA data quoted in the SEC's December 2022 liquidity proposal. The middle-office figures are one provider's own service, from its 2023 factsheet.
Show the numbers
Measure
T+ business days
LSTA standard
7
Median, July 2021
15
Middle-office average, buy side (2023 factsheet)
16
Average, July 2021 (a seven-year high)
23
Middle-office average, sell side (2023 factsheet)
23
The SEC's 2022 liquidity proposal gave the most detailed public snapshot. Around 2016, "the median settlement time for a loan sale was about 12 days." By July 2021, "the average time to settle a bank loan par trade in the secondary market increased to a then seven-year high of T+23, and the median was at T+15." Just 20% settled inside the LSTA guideline that month, and trades settling later than T+20 had risen ten points to a 39% share, "nearly double that of the T+7 distribution."5
Nearly four par trades in ten took longer than T+20 in July 2021
39 in 100
US par loan trades settled later than T+20 in July 2021, up ten points on the year before
US par loan trades settled later than T+20 in July 2021, up ten points on the year before
39 of 100
What the published settlement times tell a desk
Average above median means a tail. Most trades are a little late and a few are very late; the few carry most of the delayed compensation.
Stress can shorten settlement. The LSTA told the SEC that settlement times fell when loan funds faced heavy outflows in August 2011, and the SEC understood the same of March 2020.5
Some firms do better than the market. One middle-office provider reports average par settlement of T+16 for its buy-side clients and T+23 for sell-side clients, and says that for many firms "the average par trade settlement time remains upwards of 20 days."20
Long tails are normal. An administrator's quantitative team wrote in 2022 that par LSTA loans typically close in under 25 business days and that 60 to 90 days "are not rare."21
Europe works on the same problem. The Loan Market Association reported that 2024 settlement times fell 10% on average and 11% at the median against 2023, against a goal of 25%.22
What the public record lacks. No public source gives 2024–2026 par medians, distressed settlement times, or settlement times by cause. The LSTA's quarterly Secondary Trading & Settlement Study measures "par and distressed settlement times," including the share inside the guidelines, for its members.23 Measure your own: median business days to settle, share inside T+7, and the share of late days by cause.
09 · What goes wrong
Signatures, tax forms, agency queues and silent borrowers: the usual causes of a missed T+7, and who can clear each
In shortDelays come from every firm in the chain. The two trading desks cause the early ones (allocations, confirmations, signatures); the administrator's queue and tax-form checks cause the middle ones; the borrower's consent, amendment holds and late wires cause the last ones. A desk can clear its own causes in a day, chase the counterparty's, and only read the contract and count days for the borrower's.
Cause
Why it happens
Who can clear it
1. Trade not on the platform
No automatic feed, backdated trades skipped, facility not built on the platform.2
The submitting desk
2. Allocations late or short
The buyer splits across funds after its own committee; amounts entered by hand.2
Buyer
3. Confirmation disputed
Economic terms (accrued or ticking fees, a delayed-draw portion) read differently.2
Both desks
4. Signatures
Some firms will not sign the assignment until the confirmation is fully signed; signatory lists change; the wrong form is signed.2
The signing side
5. Buyer not eligible
Not an eligible assignee or on a disqualified list; "extensive or terminal delays."2
Nobody quickly; may end as a participation
6. Administrator's queue
Review and acknowledgment "often last three or more days"; FATCA validations.2
Administrator
7. KYC and tax forms
Questionnaire incomplete, a W-8BEN-E past its third calendar year-end.10
Buyer
8. Borrower consent
Requested late, refused, or never answered; deemed consent not counted.7
Our reading of the sources2,7,21 · Positions are our reading of the delay points the sources describe; no source measures them.
Show the numbers
Item
How long it usually holds a trade (0–1)
How much the trading desk controls it (0–1)
Signatures
0.12
0.80
Allocations
0.20
0.60
Confirmation dispute
0.30
0.70
Tax forms, KYC
0.10
0.26
Administrator queue
0.78
0.31
Borrower consent
0.80
0.20
Amendment holds
0.74
0.10
Three patterns stand out in the sources. Settlement slows as month-end and especially quarter-end approach, Mondays settle least, and loans that trade rarely settle more slowly than active ones.21 Delays also compound: a trade waiting on a signature at T+4 reaches the administrator after its quarter-end pause, and a consent request sent at T+15 has a deemed-consent window that ends after T+20.
10 · When settlement fails
When a loan trade stalls or fails: participations, buy-ins, late money and funds that need cash
In shortFew loan trades fail outright; they drag, or end in a weaker form. A refused consent turns an assignment into a participation; a non-performing counterparty can be bought in or sold out from T+20; a slow wire now costs a late payment fee. The costs land as delayed compensation, market risk on an open position, funding drag for loan funds, and staff time.
Consent refused
An accidental participant
The buyer holds "only a beneficial interest in the loan," and disputes follow between participants who want control and sellers "unhappy or unwilling to do the participant's bidding."7
Counterparty will not perform
Buy-in and sell-out
From T+20 the performing side may close out and enter a cover trade, with an indemnity for market losses. It cannot be used where the borrower's or administrator's consent is the delay.2
Money arrives late
The 2026 fee
A price paid two or more business days after the effective date can be invoiced for interest over the late period, at the loan's rate or the cost of carry rate.14
What a long settlement risks
Market risk. The price is fixed at the trade date and paid at settlement, so "the market price of the loan may move materially against one or the other of the parties" in between, and both risks "are magnified the longer it takes to settle."2
Liquidity for funds. Open-end funds held about $204 billion of bank loans at the end of 2021, about 15% of the market. Loan funds lost about 13% of assets in March 2020, more than any other fund type; some used bank lines of credit to pay redemptions while sales settled, and borrowing "imposes costs that can dilute the value of the fund for remaining investors."5 The SEC noted that loan funds "experience specific trading costs related to bridging the settlement gap."5
Delayed compensation. No public figure exists for what the market pays in delayed compensation. On one desk it is the sum of each late trade's daily rate, the bars in section 07, times its calendar days late.
Positions that never close. A participation leaves the seller in the lender group as a pass-through for the life of the loan, with voting requests to forward and payments to pass on.
39%
of par trades settled later than T+20 in July 2021, the point at which buy-in and sell-out become available.5
SEC 2022 proposal, citing LSTA data
13%
of bank loan funds' assets left in March 2020 through redemptions, more than any other fund type.5
SEC, 2022 proposal
2 days
after the transfer is effective, a price still unpaid becomes liable to a late payment fee under the May 2026 terms.14
Alston & Bird, May 4, 2026
11 · The market
$971 billion traded in 2025: record secondary loan volume, and more trades through the same agency banks
In shortUS secondary loan trading reached a record $971 billion in 2025, up 18% on 2024, and a quarterly high of $288 billion in the first quarter of 2026, taking the trailing twelve months above $1 trillion for the first time. Volume fell 18% in the second quarter and 4% in the third. Every trade is a settlement to work, through the same agency banks and the same borrowers.
Secondary loan trading set a record in 2025 after a six-year low in 2023
US secondary loan trading volume, LSTA trade data studies
The LSTA's public summaries give the shape. 2023 was "an off-year as volumes fell 13% to a six-year low of $715 billion"; 2024 rose 15% to $821.4 billion, "just $3 billion short of 2022's record $824 billion"; 2025 reached "$971 billion, up 18%."24,25 The first quarter of 2026 brought "a quarterly high of $288 billion" and twelve-month volume "surpassing $1 trillion for the first time"; the second quarter fell 18% "as volatility subsided"; the third fell 4%.25,26,27
What drives the work, besides volume
Leverage. Nearly half of all Shared National Credit commitments in the 2025 review were leveraged, and leveraged loans made up 81% of the non-pass ones.1 Weaker credits mean more amendments, more holds and more distressed documentation.
More kinds of buyer. US banks hold under half of the large syndicated commitments.1 Every new fund is a new questionnaire, a new tax form and, for many agreements, a borrower consent.
Borrowers choosing their lenders. Consent refusals rose with financial stress in 2022–23.7
Funds' liquidity. The SEC's 2016 rule made settlement time a fund compliance question; its 2022 proposal to tighten it was not adopted.11,12
The LSTA's monthly and quarterly studies carry the detail behind these totals (by month, par and distressed, settlement times) for members.23
12 · Automation and AI
Platforms, middle offices and tools that read the mail: what each automates in loan settlement, and how the April 2026 bank guidance applies
In shortMost settlement software moves documents and status between the parties. Newer tools read the mail, the notices and the credit agreement, work out what holds each trade and draft the chase. For a bank desk, the April 2026 model risk guidance, the third-party guidance and the bank's own controls apply; for any desk, people should keep every message to a borrower, every delayed compensation claim and every settlement date.
What each layer of tooling does
Platforms carry documents; reading the contract and the mail is the newer layer
Which settlement tasks each kind of tool usually covers
Not coveredBy handPartlyCovered
Settlement platformSpreadsheet and mailboxMiddle-office serviceReading and drafting softwareConfirmations and assignmentsCoveredBy handCoveredBy handStatus of each tradePartlyBy handPartlyCoveredWhat actually holds the tradeNot coveredBy handPartlyCoveredTransfer clause and deemed consentNot coveredBy handBy handCoveredChases with evidenceNot coveredBy handPartlyCoveredDelayed compensation workingPartlyBy handPartlyCovered
Our reading of the sources2,20,21 · Our classification; products differ. 'Partly' means the task depends on the people running it.
Show the numbers
Settlement platform
Spreadsheet and mailbox
Middle-office service
Reading and drafting software
Confirmations and assignments
Covered
By hand
Covered
By hand
Status of each trade
Partly
By hand
Partly
Covered
What actually holds the trade
Not covered
By hand
Partly
Covered
Transfer clause and deemed consent
Not covered
By hand
By hand
Covered
Chases with evidence
Not covered
By hand
Partly
Covered
Delayed compensation working
Partly
By hand
Partly
Covered
Model risk, third-party and AI guidance for a bank desk
Model risk. On April 17, 2026, the Federal Reserve (SR 26-2), the OCC (Bulletin 2026-13) and the FDIC (FIL-15-2026) replaced SR 11-7 with revised guidance. Simple arithmetic and fixed rules, such as a business-day count or the delayed compensation formula, fall outside its definition of a model, and it leaves generative AI and AI that acts on its own out of scope; banks govern those tools under their broader risk management.28
Third parties. A bank that buys software or a settlement service remains responsible for it under the 2023 interagency guidance on third-party relationships; revisions were proposed on September 15, 2026.29
Voluntary frameworks. NIST's AI Risk Management Framework asks users to map, measure and manage the risks of an AI system, and to keep humans able to oversee it.30
What software cannot speed up, and what stays with people
Software cannot make a borrower answer or an administrator process faster. It can make sure every request goes out on the first day it could, that every reply is read the morning it arrives, and that the days are counted from the right notice under the right definition. Silence should never count as consent without the clause and the proven notice date; a claim should never be raised without its working; and a borrower should hear from a person the bank has approved to write to it.
13 · How desks work today
A day on a loan settlement desk: trade closers, buyers' operations, the agency bank's transfer team and the borrower's treasurer
In shortA settlement analyst or trade closer owns each trade after the trader books it and chases five other parties through a shared mailbox and a platform. Most elapsed days are spent waiting in another firm's queue. Teams work in house with a platform and spreadsheets, outsource to a middle-office provider, or add software that reads the traffic for them.
Five parties every settlement depends on
SA
Settlement analyst or trade closer
Owns the trade after booking: confirmation, allocations, signatures, platform status, funding memo, wires, delayed compensation, chasing.
Cares about: knowing which of 40 open trades to chase first.
CP
Counterparty's operations
A dealer's settlement team, a CLO manager's operations staff or an outsourced middle office; allocates, signs, sends tax forms, funds.
Cares about: getting the position before its fund's own deadlines.
TA
Agency bank transfer team
Reviews each assignment, runs KYC and tax checks, sends consent requests to the borrower, records the transfer. Works for the whole lender group, whoever traded.
Cares about: complete packages, the first time.
BT
Borrower's treasurer
Receives consent requests, sometimes with the sponsor's view on which lenders are welcome.
Cares about: who will vote on the next amendment.
OM
Head of loan settlement operations
Approves large claims, reports settlement performance and delayed compensation, owns staffing.
Cares about: why the desk paid what it paid this month.
How one par trade moves from firm to firm
One par trade by assignment passes through five firms' hands
1Booked and confirmed
Trade on the platform, confirmation sent.
Seller's closerT+0 to T+1
2Allocated and signed
Buyer splits across funds; both sign the assignment.
Who held the example trade for each of its 26 business days
The borrower's ten-day window and the administrator's week took two-thirds of the time
Business days from trade to settlement, by who held the trade
Both trading desksAgency bank reviewBuyer's expired tax formBorrower's consent windowFunding and recording
26 business days47410
Fictional example from this guide · Worked from the example's dated trail: T+0 to T+4 desks; T+4 to T+9 and T+13 to T+15 agency bank; T+9 to T+13 tax form; T+15 to T+25 borrower; T+26 settlement.
Show the numbers
Both trading desks
Agency bank review
Buyer's expired tax form
Borrower's consent window
Funding and recording
26 business days
4
7
4
10
1
Only four of the 26 days belonged to the two desks that agreed the trade. That is typical of the published delay points: the parties to the trade control the first week, and the firms outside it control the rest.2
Spreadsheet desks, middle-office services and reading tools
In house
A platform, a mailbox and a spreadsheet
Analysts read the shared inbox and the agency banks' notices each morning and keep a tracker by hand. Cheap and flexible; the weak points are what nobody read, days nobody counted and claims nobody can reconstruct.
Outsourced
A middle-office service
A provider closes trades for the firm; one large service settles over 23,000 buy-side and 22,000 sell-side allocations a month.20 The firm still owns the claims, the counterparties and the results.
Software
Tools that read the traffic
Software that reads the mailbox, notices and credit agreements, names what holds each trade and drafts the chase, with people sending and signing. They differ on evidence, clause reading and how claims are worked out.
Part B · See it working
Inside one settlement desk's morning: Botminds Loan Trade Settlement on 42 open par trades at a fictional bank
Part A described the work without naming a product. This part shows how Botminds does it for the settlement desk of Ellisford Bank, a fictional bank that trades syndicated loans, on the morning of Tuesday, October 13, 2026. Every bank, fund, borrower, person and number in the screens is sample data. One word to know before you look: the screens say "agent" for two things, the bank that runs a loan (its administrative agent, as credit agreements call it) and the software agents that read and draft for the desk.
14 · One trade, start to finish
The Corvane sale on day 23: from a pipeline card marked "borrower" to a notice that sets Friday's settlement
In shortThis is the example from the top of the page, inside the product. At 8:02 a.m. the agents read 46 overnight messages and notices, and the Corvane trade lifts out of the borrower consent column with a way through: consent is deemed given in two business days. Nina Callery, the settlement analyst, checks the evidence, opens the clause, and sends the drafted notice to the buyer and the administrator. The trade is set to settle on Friday, October 16.
1
Every open trade, aged and named
The pipeline holds all 42 open par trades, $262.5 million of them, in six columns from trade confirmed to settled. Each column shows its count, its median age and an aging bar; each card shows the trade's T+ age, side, size, counterparty, the blocker in one line with a tag for who holds it (us, counterparty, agent or borrower), the delayed compensation per day and its owner.
After the 8:02 a.m. reading, the Corvane card at T+23 lifts out of the borrower consent column: "Consent deemed given in 2 days — notify counterparty", with $23,581 of delayed compensation saved.
The settlement pipeline. 42 open trades by stage, each with its age, blocker, holder and daily delayed compensation; the Corvane trade lifted out with the way through.
2
Where the 23 days went
Nina opens trade 4417. The timeline places every message and platform event on the T+ scale: confirmed at T+0, assignment and pricing letter signed at T+3, submitted to Brackwell Agency Services at T+4, a KYC hold from T+9 to T+13 while the buyer replaced its expired W-8BEN-E, agent consent at T+14, and the borrower silent since the request.
The dashed bars are the projection: deemed consent at the end of Thursday, October 15, the funding memo, settlement on Friday, October 16.
Where the days went. Each step and who held it, with T+7 and today marked; dashed bars are projected.
3
The evidence, and the money
"What is holding it" quotes three pieces of evidence, each numbered to its source: Brackwell's notice that the consent request reached Corvane's treasurer on Wednesday, September 30; the deemed consent proviso in §10.06(b)(i)(A) on page 142; and Brackwell's 7:58 a.m. transfer report, "No objection recorded." A ten-box clock shows business days 1 to 8 gone, Columbus Day skipped.
Beside it, the delayed compensation panel works out $53,593 owed so far, $2,144 a day, and the two futures: $60,024 settling on deemed consent, $83,605 waiting for a written reply.
What is holding it. The blocker with three cited quotes, the consent clock, and delayed compensation worked out both ways. The 4.31% carry rate is the sample desk's setting; LSTA terms use the period's average SOFR plus 0.11448%.4 The screen's "8 business days" counts from Thursday's deemed date; the two settlement dates, Friday, October 16 and Tuesday, October 27, are seven business days apart.
4
The clause, read and marked
"Open §10.06" shows the transfer section of Corvane's credit agreement with the margin notes the blocker finder wrote: why the borrower must consent at all (Alderbrook CLO 2024-1 is not a lender, an affiliate of one or an approved fund), the $1,000,000 minimum met, the disqualified lender schedule checked, and the Business Day definition that excludes New York bank holidays.
The agreement is fictional. Real agreements vary in the length of the window, and some have none.8
The transfer clause. The deemed consent proviso highlighted, with notes applying each condition to this trade. The contract text is the fictional agreement's.
5
A notice drafted with its proof
"Notify counterparty" opens the chase writer's draft to Rhea Lindqvist at Alderbrook, copying Hana Sato at Brackwell: the notice date, the section, the ten business days, the end of Thursday, October 15, a request to Brackwell to confirm no objection and put the trade on Friday's close list, and a reminder that delayed compensation continues from September 18 under the confirmation.
Nina edits nothing and sends it. The message goes to the buyer, so it needs no desk head approval; that step applies only to messages to a borrower.
Notify the counterparty. The draft names the notice, the clause and the date, and asks each party for the one thing it must do.
6
Set to settle Friday
The card turns to "Alderbrook and Brackwell told", a planned card appears in the settled column for Friday, October 16, and the callout records the send time. Delayed compensation stops at $60,024; waiting for a reply would have cost $83,605.
If Corvane objects before the window closes, the trade goes back to borrower consent and the desk head decides the next message to the borrower.
Notified. The trade marked as told, a planned settlement card for Friday, and the saving recorded.
The $23,581 is the fictional example's figure. The solution's design targets are a named blocker on every open trade at every 30-minute reading, and a median of T+12, to be measured on your own book.
15 · Every screen
The reading log, the inbox, nine drafted chases, delayed compensation both ways, scorecards and the monthly report
In shortOne trade is the story. These screens show the rest of the desk's morning: the reading step by step, every overnight message tied to its trade, the chases drafted to seven firms, delayed compensation owed and receivable by who is holding each trade, how long each agency bank and counterparty takes, the month's performance, and the settings that encode the desk's rules.
This morning's reading. Each step of the 8:02 a.m. run: 46 messages, the platform, the agency banks' notices, six transfer clauses, nine chases.
The thread and the run log. Nine messages from September 9 to today, each labeled with what it means, and how the agents reached the finding.
Mail and notices. Overnight messages from the mailbox, three agency banks' portals and the platform, each tied to its trade and read for what it changes.
Drafted chases. Nine messages to the person who holds each trade, each with why now and the proof; the analyst edits, sends or skips.
Delayed compensation. What the desk owes and is owed on every trade past T+7, split by who is holding it. Nothing is booked from here. Rates and the carry setting are the sample's.
Agency banks and counterparties. Median business days at consent by agency bank over 90 days, and each counterparty's outstanding steps and delayed compensation.
Settlement performance. Median days by month, the causes of September's late days, and delayed compensation paid and received, written from the trade records.
Clocks, approvals and sources. The desk's rules as settings. The sample uses a fixed monthly carry rate; LSTA terms define it as average daily SOFR plus 0.11448%, so a live desk sets it from the formula.4
Select any screen to open it larger. The inbox crop stops above a sample notice whose tax form expiry date does not follow the IRS rule (a W-8BEN-E runs to December 31 of the third year after signing).10
The desk's six months, from the report screen
The sample desk's share of trades settled inside T+7 rose from 21% to 34% in six months
Par trades settled, April to September 2026
0%10%20%30%40%34%
AprMayJunJulAugSep
Fictional example from this guide · Sample data on the report screen; its median fell from T+14 to T+11 over the same months.
Show the numbers
Settled inside T+7
Apr
21%
May
24%
Jun
26%
Jul
29%
Aug
31%
Sep
34%
Tax forms and KYC caused a third of the sample desk's late days in September
Share of late days past T+7, by cause
KYC and tax forms34%
Documents unsigned or wrong24%
Borrower consent21%
Agency bank queue13%
Funding and wires8%
Fictional example from this guide
Show the numbers
Cause
Share of late days
KYC and tax forms
34%
Documents unsigned or wrong
24%
Borrower consent
21%
Agency bank queue
13%
Funding and wires
8%
16 · Agents, and who decides
Who sends, who approves, and what the six agents prepare for them
In shortEach agent has one job and lines it does not cross. None of them sends a message, changes a trade's economics, books delayed compensation, or treats silence as consent without the clause and the notice date. The settlement analyst sends every chase and sets settlement dates; the desk head approves anything to a borrower; the head of operations approves claims over $50,000.
What each agent prepares
Trade intake reader
Reads confirmations, allocations and the settlement platform's status, and keeps one record per open trade: facility, side, counterparty, fund, amount, price, trade date, documentation type.
Never changes a trade's economics; a difference becomes a question.
Mail and notice reader
Reads the settlement mailbox and the agency banks' notices and daily reports every 30 minutes, ties each message to its trade and says what it changes.
Never sends or replies.
Blocker finder
Names what holds each trade and who holds it; reads the transfer section for deemed consent, minimums, approved funds and disqualified lenders; counts business days on the agreement's calendar.
Never treats silence as consent without the clause and the proven notice date.
Chase writer
Drafts each chase to the person who can clear the hold, with the message, notice or clause that proves it.
Never sends, and never writes to a borrower without the desk head.
Delayed comp calculator
Accrues delayed compensation from T+7 (T+20 distressed) both ways from the confirmation's terms, shows the working, and marks buyers that missed their own T+5 duties.
Never books or pays a claim.
Settlement reporter
Writes the weekly and monthly report: median days, share inside T+7, causes of late days, delayed compensation paid and received.
Never reports a figure that does not tie to the trade records.
Where a person must act before anything leaves the desk
Sends and schedulesSettlement analystSends every chase and notice, sets settlement dates, confirms or overrides each blocker.
Approves borrower messagesDesk headApproves any message to a borrower before it goes, including a request to confirm or reconsider consent.
Approves claimsHead of settlement operationsApproves delayed compensation claims over $50,000 and owns the clocks and carry setting.
Every read, draft, send and approval is kept on the audit trail with the evidence behind it, so a disputed claim or a borrower's challenge can be answered from the record.
Ellisford's team and its counterparts in the sample data
Fictional, from the sample data
NC
Nina Callery · loan settlement analyst, Ellisford Bank
Owns 17 of the desk's 42 open trades; starts each day in a 200-message shared mailbox.
"I know it's stuck. I don't know who it's stuck on until I read the whole thread."
LB
Leo Brandt · trade closer
Signs assignments and pricing letters, handles wires.
"Half my chases go to people who already sent it, to someone else."
MH
Marcus Hale · head of loan settlement operations
Approves delayed compensation claims over $50,000; reports monthly.
"I pay delayed comp every month and can't tell you why."
HS
Hana Sato · transfers associate, Brackwell Agency Services
Runs KYC and consent on hundreds of transfers for the loans Brackwell administers.
"If the buyer sent a current W-8 the first time, it would be done."
What the desk connects and what it gets back: the mailbox, agency bank notices and credit agreements, read into cited blockers, chases and claims
In shortIt reads what a desk already receives: the platform, the shared mailbox, the agency banks' portals and the credit agreements. It leaves behind a pipeline with a cited blocker on every trade, chases ready to send, delayed compensation worked out both ways, scorecards and a monthly report. The platform and the trading systems stay where they are.
From the market
Settlement platform status and documents
The shared settlement mailbox
Agency banks' notices, portals and daily transfer reports
Counterparties' allocations, signatures and tax forms
From the desk
Open trades from the trading system
Credit agreements' transfer sections
Clocks: T+7, T+20, the business day calendar
Chase timing, approvals and claim limits
Agents read, find, draft and countEvery message tied to its trade, every 30 minutes, under your desk's rules
The analyst sends every chase
Every blocker cited
Outputs
Open trades by stage and age, each with its blocker and holder
Chases drafted to the right person with the proof
Deemed consent dates, counted and cited
Delayed compensation per trade, both ways, with the working
Agency bank and counterparty scorecards
Weekly and monthly settlement performance
What changes on the desk
The morning starts from a ranked list of holds
The most expensive trade is chased first
Claims arrive with their arithmetic
Eight systems to line up before you start
Settlement platformTrade status, documents, close lists
Shared mailboxRead-only access to the settlement inbox
Agency bank portalsNotices and daily transfer reports
Trading and position systemOpen trades, funds, prices
Document storeCredit agreements and amendments
Loan accountingWhere approved claims are booked
Identity and accessWho may send, approve and claim
Holiday calendarsNew York and any other business day definitions
For each, check whether it offers an API, a file feed or only screens, and who owns it.
Alongside your platform, middle office and controls
Your settlement platform
Stays where it is. Its status is one input among several, read beside the mail and notices that explain it.
Your middle-office provider
Keeps closing trades. The desk sees what holds each one and what it costs, with the provider's messages read like any other.
Your trade documents
The LSTA confirmation terms you trade on set the clocks and the delayed compensation rules the calculator applies.
Your credit agreements
Read for each trade's transfer conditions, with the clause cited in every finding.
Your controls
Become settings: who sends, who approves borrower messages, the claim limit, the reading cadence.
Your auditors
Get a record of every read, draft, send and approval, with the evidence behind each.
How each finding is held to its evidence
1
Every blocker carries its proof
The message, notice or clause behind it, one click away, with every figure's working.
2
Silence is consent only by contract
Counted from the proven notice date, on the agreement's own Business Day definition.
3
People send every message
The analyst sends; the desk head approves borrower messages; the manager approves large claims.
18 · The book that morning
Ellisford's 42 open trades on October 13: who they were waiting on, and what the late ones cost each day
In shortAcross the sample desk's book, 26 of 42 trades were past T+7. The desk paid $10,510 a day on 16 late sales and received $3,512 a day on 10 late purchases. Of the $151,343 it owed so far, $91,576 sat on trades waiting on a borrower. Those figures come from the screens and show what a desk can see when every trade names its holder.
Of 42 open trades, 6 were waiting on a borrower that a clause might answer
The sample desk's open par trades, Tuesday, October 13, 2026
Open par trades42
Past T+726
Past T+7 and waiting on a borrower6
With a deemed consent date found1
Fictional example from this guide
Show the numbers
Stage
Count
Open par trades
42
Past T+7
26
Past T+7 and waiting on a borrower
6
With a deemed consent date found
1
Most of what the desk owed sat on trades waiting on a borrower
Delayed compensation owed so far on sales past T+7, in dollars, by who holds the trade
Borrower91,576
Counterparty50,217
Agency bank5,390
The desk itself4,160
Fictional example from this guide · The four holders add up to the $151,343 owed on 16 late sales.
Show the numbers
Holder
Owed so far ($)
Borrower
91,576
Counterparty
50,217
Agency bank
5,390
The desk itself
4,160
T+12
median days to settle: the solution's design target, against the July 2021 market median of T+15 and average of T+23.5
Design target · SEC 2022 proposal, LSTA data
42 of 42
open trades with their blocker and holder named at every 30-minute reading.
Design target
$23,581
saved on one $25 million sale by settling on deemed consent instead of waiting for a reply.
The fictional example
Part C · Are you ready to automate?
Automating loan trade settlement: the dollars behind each late day, a sixteen-point readiness score and a ten-week trial
You settle loan trades, run the team that does, or sign off on what it pays. This part is written for you: what late settlement costs today, what a reading and drafting tool could return, whether your desk is ready, and what to ask any vendor of loan settlement software or services, including us.
19 · What late settlement costs
What a selling desk pays for every day past T+7, and the costs that sit outside the claim
In shortStart from your own book. The market publishes how late trades run, but no one publishes what desks pay in delayed compensation or spend chasing. The formula in section 07 turns your late sales into dollars a day; your mailbox and your claims file give you the rest.
20 in 100
US par loan trades settled inside T+7 in July 2021, nine points below the previous year's monthly average.5
SEC 2022 liquidity proposal, citing LSTA data
T+23
was the average par settlement time that month, a seven-year high; the median was T+15.5
SEC, December 2022 proposal
$971B
of US loans traded in the secondary market in 2025, a record, each trade a settlement to work.25
LSTA, 1Q26 study summary
A $25 million sale past T+7 costs about $2,200 for every calendar day
Net delayed compensation per day, by amount sold at par, SOFR + 3.25% loan, SOFR 3.85%
$2 million$174
$5 million$435
$10 million$871
$25 million$2,177
Illustrative · replace with your own numbers · Interest at 7.10% less carry at 3.85% + 0.11448%, 360-day basis. Use your loan's rate and the period's average SOFR.
Show the numbers
Amount sold
Per calendar day
$2 million
$174
$5 million
$435
$10 million
$871
$25 million
$2,177
What nobody publishes. There is no public figure for delayed compensation paid across the market, for the share of trades that end as participations, for hours spent per trade, or for 2024–2026 settlement medians outside the LSTA's members' studies. Measure your own.
Where your desk's own figures sit, and how to pull them in a week
Cost
Where it hides
How to find your number in a week
Delayed compensation paid
Funding memos, netted monthly with frequent counterparties
Add up last quarter's claims paid on sales, trade by trade
Compensation forfeited
Purchases where your own documents were late at T+5
List purchases with no claim and check the T+5 dates
Days lost to borrowers
Consent requests nobody counted
For ten consent trades, compare the deemed consent date with the actual settlement
Chasing time
The morning mailbox and repeated reminders
Ask two analysts to log chasing minutes for a week
Late payments
Prices received days after the effective date
Compare effective dates with cash receipts for a month
Disputed claims
Threads arguing start dates, rates and day counts
Count claims reworked in the last quarter and why
What late settlement costs that never shows on a funding memo
The position you could not sellA buyer that waits weeks for a trade remembers it at the next auction.
Market moves on open tradesThe price is fixed at the trade date; a long settlement leaves both sides exposed.
The participation you now administerA trade that could not be assigned stays on your books as a pass-through for the life of the loan.
Fund redemptionsA loan fund waiting on sales may draw on a credit line to pay investors.
Your analysts' attentionSpent working out which thread matters before any trade moves.
20 · Your return
The return on faster settlement, worked from your late sales, position size and chasing hours
In shortPut in your own numbers. The calculator values the calendar days you take off late sales at the delayed compensation rate, and the chasing hours you take off every trade. Every default marked illustrative is an assumption to replace.
Where faster settlement pays, lever by lever
Delayed compensation
Fewer days on late sales
Holds named the morning they start; the costliest trade chased first.
late sales × size × net rate ÷ 360 × days saved
Borrower consent
Deemed consent counted
Every consent trade with its window end date, so silence is acted on the day it becomes consent.
consent trades × days between the deemed consent date and the actual settlement × daily rate
Forfeits
Your own T+5 duties met
Purchases where your signatures were late keep their compensation.
late purchases kept × days late × daily rate
Staff time
A ranked list of holds each morning
Messages read and tied to trades; chases drafted with the proof.
trades × hours saved × loaded hourly cost
Claims
Arithmetic attached
Start date, rate, carry and day count shown, so disputes end sooner.
claims reworked × hours per rework × hourly cost
Late money
Payments matched to effective dates
Late receipts flagged for the 2026 late payment fee within its 30-day invoice window.
late receipts × days late × applicable rate
Put your own late sales into the formula
The net rate default is worked from the LSTA formula for an illustrative loan at SOFR plus 3.25% traded at par: 3.25% less the 0.11448% spread adjustment, rounded.4,18 Every input marked illustrative is an assumption.
Your late salesYour time and cost
Illustrative yearly value
Delayed compensation paid on late sales today$0
Delayed compensation avoided$0
Chasing time released, valued$0
After your yearly cost$0
Analyst hours released a year0
Formulas, per year: Paid today = late sales × amount × net rate ÷ 100 ÷ 360 × days late today Avoided = late sales × amount × net rate ÷ 100 ÷ 360 × (days late today − days late with the tool) Time released = trades × (hours today − hours with the tool) × hourly cost After your cost = avoided + time released − yearly cost
Counts sales only: on purchases a faster settlement means less compensation received and the position sooner, which roughly nets out. Not counted: forfeits avoided, late payment fees collected, disputes avoided, market risk on open trades. At par the net rate is the loan's margin less 0.11448%, whatever SOFR does; below par it grows with the discount and with SOFR (section 07).
The calculator's defaults: five fewer late days per sale and two fewer hours per trade
TodayWith the tool
Calendar days past T+7 per late sale149
Chasing hours per trade31
Illustrative · replace with your own numbers · Assumptions to replace with your own baseline; measure both in a pilot.
Show the numbers
Today
With the tool
Calendar days past T+7 per late sale
14
9
Chasing hours per trade
3
1
A desk that sells a few hundred late positions a year carries most of its value in the first line; a desk that mostly buys carries it in staff time and forfeits avoided. Run it with your own quarter before you decide anything.
Start here21 · Readiness check
Is your settlement desk ready for software that reads the mail and the credit agreements? Eight scored questions and one to reflect on
In shortPick the answer closest to your desk today. Eight questions score 0 to 2; the last is for reflection. The meter adds up your score as you go, and each question says why it matters and what a strong answer sounds like.
1
Volume
How many trades does your desk settle a year, both sides?
Why it mattersVolume turns minutes per trade and days per late sale into money.
A strong answer"About 1,500, two-thirds sales, mostly par, a few dozen distressed."
2
Your baseline
Do you know your median business days to settle, your share inside T+7, and what you paid in delayed compensation last quarter?
Why it mattersNo current public benchmark exists, so your own numbers are the only way to show improvement.
A strong answer"Median T+14, 22% inside T+7, $1.1 million paid and $400,000 received last quarter."
3
Causes
Can you say what share of your late days each cause takes: documents, tax forms, the agency bank, borrowers, money?
Why it mattersThe cause mix decides where the days come back. A desk losing days to borrowers gains most from reading clauses.
A strong answer"About a third tax forms and KYC, a fifth borrower consent, the rest documents and agency queues."
4
Where the messages are
Does settlement traffic arrive in places software can read: one shared mailbox, the platform, the agency banks' portals?
Why it mattersA tool can only tie messages to trades it can see. Personal inboxes and phone calls stay invisible.
A strong answer"One shared mailbox, the platform feed, and portal access for our three biggest agency banks."
5
Credit agreements
Can you put your hands on the current credit agreement, with amendments, for every loan you trade?
Why it mattersDeemed consent, approved funds, minimums and disqualified lenders are all in the transfer section.
A strong answer"Yes, in our document store, by facility, amendments included."
6
Claims
Are delayed compensation claims worked out the same way every time, both ways, with the working kept?
Why it mattersA tool can only match a method that exists. The working is also what settles disputes.
A strong answer"One method on the LSTA terms, both directions, every claim with its start date, rates and day count."
7
Approvals
Are the rules written down for who may write to a borrower, who sets a settlement date and who approves large claims?
Why it mattersThose rules become the tool's approvals. Unwritten rules become arguments.
A strong answer"Desk head approves borrower messages; claims over $50,000 go to the head of operations."
8
Owner and approvals to share data
Is there one owner for settlement performance, with the approvals to let a vendor read trade data and mail?
Why it mattersPilots stall on access: vendor risk and information security reviews take weeks.
A strong answer"The head of loan operations owns it; vendor risk has a path for read-only mailbox access."
9
Vision · for reflection
If your head of operations asked at 9 a.m. which ten open trades cost the most today, who holds each one and what the documents allow, how long would the answer take, and what would it rest on?
Why it mattersYour answer lists the gaps: reading, tying, counting, citing or ranking. Each is a candidate job for software.
A strong answerA short list, for example: "every trade's holder from the latest message, deemed consent dates counted, the daily rate beside each."
Three bands, and the next step for each
0–6
Explore
Measure first: a month of settled trades with median days, share inside T+7, delayed compensation both ways and late days by cause. Move settlement mail into one shared box. Start narrow, for example with deemed consent dates on every trade waiting on a borrower.
7–11
Ready to pilot
Run a measured pilot on your own open book: replay a closed month to test the findings against the trades' known outcomes, then run beside the desk on live trades with your analysts sending every message.
12–16
Ready to implement
Plan the full desk: every source connected, approvals as settings, claims and reporting from the tool, and the audit evidence your controllers and auditors will ask for.
22 · Questions for any vendor
Sixteen tests for loan settlement software or a settlement service: reading, consent clauses, delayed compensation and evidence
In shortAsk every vendor the same questions, us included. The answers show whether a tool moves documents or reads them, whether it can find the real hold and the way through, whether its delayed compensation matches the LSTA terms, and what evidence you keep.
Ask
A good answer
A warning sign
What it reads
Which sources does it read: the platform, the shared mailbox, agency bank portals and reports, credit agreements?
All four, with each message tied to its trade
"The platform status is the source of truth"
How does it tie an email to a trade when the subject line is wrong?
By borrower, facility, amount, counterparty and thread, with low-confidence matches asked
Subject-line matching only
What does it do with a message that changes nothing?
Reads it, says so, keeps it on the record
Drops it unseen
Finding the hold
Does it name who holds each trade, separately from the platform's status?
A named holder with the message that proves it
The platform's status copied
How does it read a transfer clause: deemed consent, approved funds, minimums, disqualified lenders, the Business Day definition?
Quotes the clause with its page, and applies it to the trade
A generic five-day rule for every loan
How does it count business days?
From the proven notice date, on the agreement's calendar, holidays included
Weekdays only
When does it treat silence as consent?
Only with the clause, the notice date and no objection on the agency bank's record
After any long silence
Delayed compensation
Which formula does it use?
Interest on the amount less carry on the price, carry at average SOFR plus 0.11448% for trades from December 1, 2021
A flat rate nobody can source
Does it know who forfeits compensation?
Flags late T+1 submissions and T+5 documents; keeps compensation when the delay is a consent
Accrues for every late trade
How does it treat distressed trades and the 2026 late payment fee?
T+20 commencement and the distressed conventions; late receipts flagged within 30 days
Par rules applied to everything
Control and evidence
Who sends a message, and who approves one to a borrower?
A named person sends; your approval rules apply
Automatic sends
Can it book or pay a claim?
No; it works out the claim and a person raises it
"It posts to accounting"
What is kept for a dispute or an audit?
Every read, draft, send and approval, with the evidence and the working
Logs only, no evidence
Proof on your book
Will it replay a closed month of your trades?
Yes, scored against what actually held each trade
Only a demonstration book
How will you measure false findings?
Wrong holders and wrong dates counted per hundred trades
One accuracy percentage
What does it need from our IT and vendor risk teams?
A written list: read-only mailbox, platform feed, document store, approvals
"We'll figure it out in the pilot"
23 · How to start
A ten-week trial on your own trades: replay a closed month, run beside the desk, then decide on four numbers
In shortMeasure first, replay a month you already know the answers to, then run beside the desk on live trades with your analysts sending every message. Decide with four numbers. None of these steps commits you to a vendor.
Measure a month: median business days, share inside T+7, delayed compensation paid and received, late days by cause.
Gather the inputs: a closed month's mailbox, platform history and the credit agreements behind it, with approvals to share them.
Replay it: score the tool's holders, deemed consent dates and claims against what happened on each trade.
Run beside the desk on live trades for four weeks, analysts sending every message and approving every claim.
Decide with four numbers: calendar days past T+7 on sales, wrong findings per hundred trades, claim differences, analyst hours per trade.
A ten-week trial ends with a decision on four numbers
Your teamVendor
Measure a month of settled trades
Approve read access; gather agreements
Load clocks, calendars and approvals
Replay the closed month
Score the replay
Run beside the desk on live trades
Decide
Week 0246810
Illustrative · replace with your own numbers
Show the numbers
Activity
From
To
Measure a month of settled trades
0
2
Approve read access; gather agreements
0
3
Load clocks, calendars and approvals
1
3
Replay the closed month
3
5
Score the replay
4
5
Run beside the desk on live trades
5
9
Decide
9
10
The figures the trial records, and why each matters
Measure
How
Why
Days past T+7 on sales
Calendar days, pilot weeks against your baseline month
The delayed compensation lever
Wrong findings
Wrong holder, wrong date or wrong clause, per hundred trades
A wrong hold wastes a chase; a wrong date risks a dispute
Claim differences
Tool claims against your own, trade by trade, with the reason for each difference
Money moves on these figures
Analyst hours
Time logs for the mailbox and chasing, before and during
The staff time lever
Deemed consent caught
Consent trades whose window end date was found the day the clause allowed
Where the largest single savings sit
The full working-session questions: 15 questions in five groups
Bring settlement operations, the trading desk, legal, compliance, controllers, vendor risk and IT into one room. Each question says why it matters, what a strong answer looks like and the warning sign.
A
Which trades are in
A1
Which trades are in: par only, or distressed too; assignments only, or participations?
Why it mattersDistressed trades run on different clocks and documents.
Strong answer · warning sign
Par first, distressed in phase two.
"Everything at once."
A2
Which agency banks and platforms carry most of our trades?
Why it mattersThree or four sources usually cover most traffic.
Strong answer · warning sign
A ranked list with trade counts.
Nobody knows.
A3
Which sales cost us most in delayed compensation last quarter, and why?
Why it mattersThe pilot should prove itself on those.
Strong answer · warning sign
Ten trades with causes.
"We don't track it."
B
Agreements, mail and calendars
B1
Where do the credit agreements and amendments live, and are they current?
Why it mattersClause reading needs the agreement in force.
Strong answer · warning sign
One store, by facility.
Shared drives and email attachments.
B2
Can the tool get read-only access to the shared mailbox and the platform?
Why it mattersReading is the first job.
Strong answer · warning sign
An approved path.
Screenshots and exports.
B3
Which business day calendars do our agreements use?
Why it mattersA missed holiday moves every date.
Strong answer · warning sign
New York, plus listed exceptions.
"Weekdays."
C
Claims and late fees
C1
Do we compute carry at average SOFR plus 0.11448% on every trade since December 2021?
Why it mattersA fixed monthly rate drifts from the LSTA formula.
Strong answer · warning sign
Yes, from the NY Fed series.
"Ops sets a rate each month."
C2
Do we check our own T+5 documents on purchases?
Why it mattersLate documents forfeit compensation.
Strong answer · warning sign
A daily exception list.
Discovered when the claim is refused.
C3
Are we invoicing late payment fees under the 2026 terms?
Why it mattersThe invoice window is 30 calendar days.
Strong answer · warning sign
Receipts matched to effective dates.
Nobody owns it.
D
Who may act
D1
Who may write to a borrower, and with whose approval?
Why it mattersThe business that owns the borrower relationship decides what is said to it.
Strong answer · warning sign
Desk head approves every message.
Anyone with the address.
D2
What claim size needs a second approver?
Why it mattersIt becomes a setting.
Strong answer · warning sign
A written limit.
"Big ones."
D3
Which vendor risk and model governance reviews apply?
Why it mattersBanks follow the third-party guidance and their own model policy.29,28
Strong answer · warning sign
Named reviewers and a timeline.
Found out in week six.
E
How you will judge it
E1
What reduction in days past T+7 would justify the cost?
Why it mattersAgree the bar before the pilot.
Strong answer · warning sign
A number, from the calculator.
"We'll know it when we see it."
E2
What error rate on findings is acceptable?
Why it mattersWrong holds waste chases.
Strong answer · warning sign
A rate per hundred trades, by type.
"None," or no measure.
E3
Who decides at the end, and on which numbers?
Why it mattersPilots without an owner drift.
Strong answer · warning sign
Head of loan operations, four numbers.
A committee, no criteria.
24 · Questions answered
What people ask about loan trade settlement: T+7, delayed compensation, cost of carry, consent and participations
In shortThe questions settlement teams and buyers search for most, each answered on its own.
What is loan trade settlement?
Loan trade settlement is the work of completing a secondary trade in a syndicated loan after the price is agreed: signing the trade confirmation and the assignment, getting the administrative agent's and often the borrower's consent, delivering the buyer's questionnaire and tax forms, agreeing the funding memo and wiring the price. The trade settles when the agent records the buyer as a lender in its register.
What does T+7 mean in syndicated loan trading?
T+7 means seven business days after the trade date. It is the LSTA's target for settling a par or near-par loan trade and the date from which delayed compensation starts to accrue. It is a term of the trade documents both sides sign; no regulator sets or enforces it.
Why do loan trades take so long to settle?
Because firms that are not party to the trade must act: the administrative agent reviews the assignment, KYC and tax forms, and the borrower may have to consent. Signatures, allocations, amendment holds and late wires add days. In July 2021 the average US par trade took 23 business days and the median 15, according to LSTA data the SEC cited in its December 2022 liquidity proposal.
How is delayed compensation calculated?
For each calendar day after T+7, the buyer is credited with interest on the traded amount at the loan's rate, and the seller keeps carry on the purchase price at the cost of carry rate. The net is usually paid by the seller to the buyer: on $10 million traded at par, with the loan paying 7.10% and carry at 3.96%, about $871 a day (an illustrative case). A buyer that missed its own deadlines, such as signing by T+5, does not receive it.
What is the cost of carry rate in LSTA loan trades?
For trades entered into from December 1, 2021, the LSTA standard terms set the cost of carry rate as the average of daily simple SOFR over the period plus a spread adjustment of 11.448 basis points. The spread equals the Federal Reserve's tenor adjustment for one-month LIBOR in Regulation ZZ.
What is the difference between par and distressed loan trades?
Par (par/near par) documents are used for performing loans trading close to face value, with a T+7 settlement clock. Distressed documents are used for loans in or near trouble; they add a purchase and sale agreement with wider representations, and the delay period generally starts at T+20. The parties choose the documents when they agree the trade.
Is borrower consent required to assign a syndicated loan?
Usually yes, unless the buyer is already a lender, an affiliate of a lender or an approved fund, or an event of default is continuing. Consent is typically "not to be unreasonably withheld", and many agreements deem it given if the borrower does not object within a set number of business days of notice. The credit agreement's assignment section decides.
What is a deemed consent clause in a credit agreement?
A deemed consent clause is a proviso that treats the borrower as having consented to an assignment unless it objects in writing within a stated number of business days after receiving notice. Periods vary by agreement; one published sample uses five business days. The window runs from the notice date and skips the holidays in the agreement's Business Day definition.
What happens if the borrower refuses consent to a loan assignment?
A trade on LSTA documents that cannot be settled by assignment settles by participation: the seller stays lender of record and passes the economics to the buyer. The buyer then has no direct relationship with the borrower and no direct vote. Courts have not settled when a refusal is unreasonable for syndicated loans.
What is the difference between a loan assignment and a participation?
An assignment transfers the lender's rights and obligations, so the buyer becomes a lender of record with voting rights once the agent records it. A participation leaves the seller as lender of record and gives the buyer a beneficial interest in the payments only. Assignments are the normal way to settle; participations are the fallback.
Do syndicated loans settle T+1 like stocks?
No. The SEC's move to T+1 on May 28, 2024 covers securities transactions by broker-dealers. Syndicated loans settle under their own trade documents and credit agreements. In Kirschner v. JPMorgan Chase Bank (August 2023), the Second Circuit upheld the dismissal of a claim that the notes in one syndicated term loan were securities, because the plaintiff had not plausibly shown that they were.
What changed in LSTA loan trading documents in 2026?
On May 4, 2026 the LSTA published amendments that add a late payment fee. A party that pays the purchase price two or more business days after the transfer is effective owes interest for the late days: the loan's all-in rate on performing loans, the cost of carry rate on non-performing, distressed, payoff and proceeds trades. The payee invoices within 30 calendar days.
What is a funding memo in a loan trade?
The funding memo states the money due at settlement: the traded amount times the price, accrued interest and fees, delayed compensation and any adjustments. The seller or the platform prepares it and the buyer agrees it before wiring the price. Differences in the memo, such as ticking fees on a delayed-draw tranche, are a common late cause.
Can software decide that a borrower has consented?
Software can read the clause, count business days from the proven notice date on the agreement's calendar and check the agent's record for an objection. The decision to schedule settlement, and any message to the borrower, should stay with named people, and silence should count only where the credit agreement says so.
25 · On one page
The settlement desk's printable page: six steps, the terms in force, the score bands and fourteen definitions
Print this page
In shortThe whole guide on one screen: the method, the terms in force as of October 2026, the readiness bands and the vocabulary.
The method
Get trade details on the platform by T+1 and documents signed by T+5.
Send the assignment, questionnaire and current tax forms together.
Read the transfer section: who must consent, minimums, approved funds, disqualified lenders, deemed consent.
Count business days from the proven notice date on the agreement's calendar.
Name the holder of every open trade each morning; chase the costliest first, with the proof.
Work out delayed compensation both ways with the LSTA formula; keep the working; pay the price on time.
Readiness: score 0–2 on eight questions: 0–6 explore · 7–11 pilot · 12–16 implement.
As of October 2026: par T+7 and distressed T+20 commencement · requirements-based delayed compensation since September 1, 2016 · cost of carry = average SOFR + 0.11448% since December 1, 2021 · late payment fee published May 4, 2026 · SEC 2022 liquidity changes not adopted · SR 26-2 replaced SR 11-7 on April 17, 2026.
14 terms
Syndicated loan
One credit agreement, many lenders, one bank running it for them.
Administrative agent
That bank: keeps the register, collects and pays, approves transfers.
Secondary trade
A sale of an existing loan share from one holder to another.
Par / near par
LSTA documents for performing loans; T+7 clock.
Distressed
LSTA documents for troubled loans, with a purchase and sale agreement; T+20.
T+n
n business days after the trade date.
Trade confirmation
The signed record of the trade, incorporating the LSTA standard terms.
Assignment and assumption
The transfer that makes the buyer a lender of record.
Participation
The economics passed to the buyer while the seller stays lender of record.
Deemed consent
The borrower's silence treated as consent after a set number of business days.
Delayed compensation
Interest on the amount less carry on the price, from T+7, for each calendar day.
Cost of carry rate
Average daily SOFR plus 11.448 basis points.
Funding memo
The settlement amount: price, accrued interest, delayed compensation, adjustments.
Buy-in / sell-out
From T+20, closing out against a party that will not perform.
26 · Sources
Sources
Accessed October 2026. Regulatory status statements are as of October 2026.
Federal Reserve, FDIC, OCC, "Agencies release 2025 Shared National Credit Program report", January 12, 2026. federalreserve.gov
A. Nolan, A. Paddock, V. Spiro, finance alert, "Better Late Than Never: The LSTA's New Delayed Compensation Standard for Assignments of Par/Near Par Loans", September 2016. files.klgates.com
Hunton Andrews Kurth, "Guidance on Revisions to LSTA Secondary Loan Trading Documentation Effective June 9, 2017", June 16, 2017. hunton.com
Alston & Bird, "LSTA Trading Documents Revised to Simplify Cost of Carry Calculation", December 7, 2021. alston.com
SEC, "Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting", proposed rule, 87 FR 77172 (December 16, 2022), pp. 77190–77191. govinfo.gov
SEC, "Shortening the Securities Transaction Settlement Cycle", final rule, 88 FR 13872 (March 6, 2023); compliance date May 28, 2024. govinfo.gov
P. Haskel and B. Hail (Crowell & Moring), "Implications of Borrowers Rejecting Assignments of Syndicated Bank Loans", Bloomberg Law Professional Perspective, June 2023. crowell.com
Law Insider, "Consent by Borrower" clause samples (deemed consent five Business Days after notice). lawinsider.com
Kirschner v. JP Morgan Chase Bank, N.A., No. 21-2726 (2d Cir. August 24, 2023). govinfo.gov
IRS, Instructions for Form W-8BEN-E (Rev. October 2021), "Expiration of Form W-8BEN-E". irs.gov
SEC, "Investment Company Liquidity Risk Management Programs", final rule, 81 FR 82142 (November 18, 2016). govinfo.gov
SEC, "Form N-PORT and Form N-CEN Reporting; Guidance on Open-End Fund Liquidity Risk Management Programs", 89 FR 73764 (September 11, 2024). federalregister.gov
P. Haskel, J. Ohlig, F. Jaklitsch (Crowell & Moring), "LSTA Proposes Introduction of Late Payment Fees in Loan Trade Transactions", January 12, 2026. crowellfintalk.com
Alston & Bird, "Revised Loan Trading Documents: New Costs, Payments", May 4, 2026. alston.com
NIST, AI Risk Management Framework 1.0 (NIST AI 100-1), January 2023. nvlpubs.nist.gov
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