28 July, 2025
Working Group Updates 7/28/2025
28 July, 2025
- FIF Trade Surveillance Webinar. FIF hosted a webinar on Trade Surveillance on Wednesday July 23. FIF would like to thank Holly Dito of Daiwa (moderator for the webinar) and Ted Karn of The Karn Group, Derek Lacarrubba of the KL Gates law firm, Chris Montagnino of Jordan and Jordan, and Scott Richard of S3 (panelists for the webinar) for their thoughtful and engaging discussion of these issues.
- SLATE Working Group. Members of the SLATE Working Group responded to surveys relating to 2026 planning and budgeting for SLATE and whether they plan to submit to SLATE in batch or real-time. The Working Group discussed the survey results. The Working Group discussed the “if known” requirement”, reporting of MPIDs for parties to a loan, reporting for loaned securities that become invalid, and scenarios involving foreign branches of a foreign bank where US personnel are involved.
- OFR Repo Reporting Working Group. The OFR Repo Reporting Working Group discussed the reporting of timestamps for trades executed manually, including by chat or telephone.
- 24x7 Trading Working Group. The 24x7 Trading Working Group discussed a proposal from an FIF member to define evening trades as having an effective trade date of the following day. The Working Group continued its discussion of the extension of TRF reporting hours and the dissemination of OTC trading activity that occurs when exchange trading is paused.
- Rule 605 and Rule 606 Working Groups. FIF hosted a joint call for the Rule 605 and Rule 606 Working Groups. The Working Groups discussed the first draft of an FIF Fact Sheet for Rule 605 presented by an FIF member. The objective of the Fact Sheet is to provide an explanation to retail investors of the purpose and content of the new Rule 605 summary report. The Working Group discussed the Rule 606(a) reporting of fees for options look-through scenarios. The Working Group discussed the current status of the implementation of the Rule 605 amendments.
- Section 31 Fees Subgroup. The Section 31 Fees subgroup discussed the discrepancy between the exchanges charging regulatory fees based on clearing activity and FINRA charging the Regulatory Transaction Fee based on TRF and ORF trading volume. The subgroup discussed expanding the information on the report currently provided by FINRA to assist clearing firms with reconciling the Regulatory Transaction Fee. The subgroup also discussed FINRA making this report available to executing firms. FIF submitted a note to FINRA to request a follow-up discussion on these issues.
- Front Office Committee. The Front Office Committee reviewed applicable updates and notices from the SEC, FINRA, FINRA CAT and the equity and option exchanges.
- CAT Transaction Reporting Working Group. FIF hosted two calls this past week for the CAT Transaction Reporting Working Group. During both calls, the Working Group discussed recommendations to manage and reduce CAT costs. During the first call, the Working Group discussed the recent updates to FAQ K10, relating to options market maker quotes. During the second call, the Working Group discussed the SEC’s extension of the current exemptive relief relating to representative order linkage. The Working Group also discussed a revised draft of the FIF request for permanent exemptive relief relating to representative order linkage.
Eduard Kotlyar