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FIF Front Office Committee

The FIF Front Office Committee focuses on order management and trading system issues resulting from regulatory changes (FINRA, SROs, SEC) as well as exchange initiatives. As new issues arise, members of this committee are notified to determine their interest in joining an issue-oriented working group. This committee meets periodically to review front office issues and determine when a new issue working group should be formed.

Please see FIF Initiative Tracking for a full list of initiatives that this committee follows.

Chairs: Irene Halpin, JP Morgan; Jess Haberman, Fidessa

Relevant Working Groups

Members of the Front Office Committee actively participate in the following working groups:

FIF/FPL Regulatory Reporting
This working group, comprised of FIF and FIX Protocol Ltd (FPL) members, works together in addressing transparency initiatives proposed by SEC and FINRA and promotes standardization in trade reporting.

FIF Short Sale Implementation
This working group will discuss areas/resources impacted, implementation issues and areas requiring clarification from SEC, SROs and other SIPs concerning the SEC Short Sale rule. The FIF Reg SHO Price Test Tracker maintains an aggregated daily list of securities triggered under the Short Sale rule.

OATS Expansion to all NMS Stocks: Relevant Links
Bi-weekly meetings tracking FIF member questions and FINRA answers related to the implementation of OATS for all NMS stocks.

Market Access
Addresses areas requiring further clarification and implementation issues associated with SEC Market Access Rule 15c3-5.

Please see FIF Initiatives Tracking for a full list of initiatives that this committee follow

FIF Front Office Meeting Agendas

Limit Up-Limit Down

June 22, 2011 - FIF Comment Letter to SEC on Limit Up-Limit Down Posted [2011-06-22]
FIF Letter to the SEC regarding scope/exemptions and implementation considerations/timing on Limit Up-Limit Down
June 22, 2011 - Limit Up-Limit Down Summary Posted [2011-06-22]
Updated Limit Up-Limit Down Plan Summary provided by NASDAQ

Meeting Materials/Minutes

January 18, 2011 - FIF Front Office Meeting Agenda Posted [2011-05-24]
Meeting Agenda including, Short Sale Updates, OATS Expansion, Market Access Rule and Dodd Frank
February 15, 2011 - FIF Front Office Meeting Agenda Posted [2011-05-24]
Meeting Agenda including, Market Access Rule, OATS Expansion, FINRA Rule 5131 and Legal Entity Identifier (LEI)
March 15, 2011 - FIF Front Office Meeting Agenda Posted [2011-05-24]
Meeting Agenda including, Short Sale Updates, FINRA Rule 5131, Flash Order Update, Rule 92/Manning and ISE Qualified Contingent Cross
April 19, 2011 - FIF Front Office Meeting Agenda Posted [2011-05-24]
Meeting Agenda including, Market Volatility, Short Sale Updates, FINRA OATS Updates, Market Access Rule, FINRA Rule 5131 Update and New Options Exchange
May 17, 2011 - FIF Front Office Meeting Agenda Posted [2011-05-24]
Meeting Agenda including, Market Access, FINRA Rule 5131 Update, FINRA OATS Updates, Limit Up-Limit Down, Stock Circuit Breaker Updates and Short Sale Updates
August 17, 2010 - FIF Front Office Meeting Agenda Posted [2010-08-17]
Meeting Agenda including Short Sale, Consolidated Audit Trail and FINRA updates
July 20, 2010 - FIF Front Office Meeting Agenda Posted [2010-07-20]
Meeting Agenda including updates from FINRA, Stock Circuit Breaker, Short Sale and Clearly Erroneous
June 15, 2010 - FIF Front Office Meeting Agenda Posted [2010-06-15]
Meeting Agenda including updates on Large Trader Reporting System, Consolidated Audit Trail, Stock Circuit Breaker and Short Sale

Current Documents

FIF Term Sheet on SEC Short Sale FAQ 2.4 and 2.5 Posted [2010-02-08]
FIF Request for Interpretive Relief With Respect to the Regulation SHO Aggregation and Marking Requirements
SEC Amendments to Short Sale - Excerpt Posted [2009-04-28]
Excerpts from the 273 page filing on Amendments to the Short Sale Rule published by the SEC on April 10, 2009.

Comment Letters

Sep 16, 2011 - FIF Comment Letter to FINRA on OATS Expansion Posted [2011-09-16]
FIF letter to FINRA regarding Testing and Production Concerns on OATS Expansion to NMS Stocks
Apr 15, 2011 - FIF Comment Letter to SEC on the Market Access Rule Posted [2011-04-18]
FIF Letter to the SEC regarding implementation timing on the Market Access Rule
Mar 18, 2011 - FIF Comment Letter to FINRA on Rule 5131 Posted [2011-03-18]
FIF letter to FINRA on implementation issues associated with FINRA Rule 5131 including definition of "commencement of trading", scope of the rule and implementation timing
Sep 17, 2010 - FIF Comment Letter to the SEC on New OATS Route Report Requirements Posted [2010-09-24]
FIF Letter to the SEC on Addition of Routed Price and Short Sale Exempt Identifier to OATS Route Reports
Sep 17, 2010 - FIF Comment Letter to the SEC on OATS Expansion Posted [2010-09-17]
FIF Letter to the SEC regarding the expansion of OATS to all NMS Securities
Aug 12, 2010 - FIF Comment Letter to the SEC on Consolidated Audit Trail Posted [2010-08-12]
FIF Letter to the SEC regarding the proposed Consolidated Audit Trail
Jul 26, 2010 - FIF Comment Letter to the SEC on Short Sale Exemptive Relief Posted [2010-07-26]
FIF Letter to the SEC requesting exemptive relief for the facilitation of Customer or Dealer Sell Short Order as Riskless Principal when Firm's position is Net Long
Jul 21, 2010 - FIF Letter to SEC on Clearly Erroneous Executions Posted [2010-07-21]
FIF Letter to the SEC regarding Exchanges and FINRA filings on Clearly Erroneous Executions
Jun 22, 2010 - FIF Letter to SEC on Large Trader Reporting System Posted [2010-06-22]
FIF Letter to SEC regarding the proposed Large Trader Reporting System
Feb 24, 2010 - FIF Comment Letter to the SEC on Publication of Certain Aggregate Daily Trading Volume Data Posted [2010-02-25]
FIF letter to the SEC regarding the use of a separate MPID for reporting the FINRA member firm's ATS dark pool transactions
Sep 23, 2009 - FIF Comment Letter II to the SEC on Short Sale Posted [2009-09-24]
FIF Letter to the SEC offering feedback on proposed Short Sale Amendments
June 19, 2009 - FIF Letter to the SEC on Short Sale Posted [2009-06-26]
FIF Letter to the SEC commenting on proposed Short Sale Amendments
April 24, 2009 - FIF Letter to FINRA and NYSE Euronext on NYSE Regulation Information Memo 09‐13 and FINRA Regulatory Notice 09‐15 Posted [2009-04-27]
FIF Letter to FINRA and NYSE Euronext Providing Feedback on NYSE Regulation Information Memo 09‐13 and FINRA Regulatory Notice 09‐15 Based on Input from FIF Members
February 19, 2009 - FIF Letter to SEC regarding SR–NASDAQ–2008–104 Posted [2009-03-23]
FIF Letter to the SEC regarding implementation issues associated with the NASDAQ sponsored access proposal
February 29, 2008 - FIF Letter to SEC regarding SR-FINRA-2007-12 Posted [2008-02-29]
FIF Letter to the SEC regarding the proposal to amend trade reporting rules to require related market center indicator on certain non-tape reports submitted to FINRA

Archive Documents

January 20, 2009 - Front Office Meeting Posted [2009-03-31]
Meeting materials for the Front Office WG Meeting. Attachment includes mockup of a Reg NMS Report Card
April 29, 2008 - Front Office Meeting Posted [2008-04-28]
Meeting materials for the Front Office WG Meeting
February 26, 2008 - Front Office Meeting Posted [2008-02-26]
Meeting materials for the Front Office WG Meeting
January 29, 2008 - Front Office / Trade Reporting WG Direction Setting Meeting Posted [2008-01-28]
Meeting materials for Front Office / Trade Reporting WG Direction Setting Meeting
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