23 June, 2025
Working Group Updates 6/23/2025
23 June, 2025
- SLATE Working Group. The SLATE Working Group discussed final changes to an FIF letter to the SEC and FINRA relating to the implementation of SLATE reporting. The Working Group discussed reporting the equityShares and parValue fields, reporting of the various MPID fields, reporting price changes, reporting the securityIdentifier field, and reporting for block trades and allocations.
- OFR Repo Reporting Working Group. The OFR Repo Reporting Working Group reviewed a draft letter to the Treasury Department’s Office of Financial Research (“OFR”) relating to the reporting of repos where the closing leg does not settle on the scheduled end date. The Working Group also discussed comments from an FIF member relating to the resubmission of reports to the OFR. After discussion with the Working Group, FIF incorporated these comments into the FIF letter to the OFR.
- Short Position Reporting. FIF hosted a call for the Short Sales / Reg SHO / Short Reporting Working Group to discuss the current status of Form SHO reporting and potential next steps for the FIF Working Group. The Working Group agreed that FIF should prepare a draft letter to the SEC to request an extension of the current compliance date for Form SHO reporting.
- 24x7 Trading Working Group. The 24x7 Trading Working Group discussed various regulations that could be impacted by the extension of exchange trading hours and how these regulations should apply for extended-hours trading. This included a discussion of limit up – limit down, clearly erroneous executions, market-wide circuit breakers, trading suspensions, the short sale circuit breaker, the Reg SHO locate requirement, the order protection rule, T+1 settlement, and same day allocations, confirmations and affirmations.
- EBS Working Group. The EBS Working Group discussed the SEC’s request for comment on the renewal of Electronic Blue Sheets reporting. The Working Group discussed EBS costs and potential alternatives to EBS.
- 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 PII and CAIS. FIF hosted a joint call for the CAT CAIS and CAT Transaction Reporting Working Groups to continue the discussion of the removal of PII from CAT. The Working Groups discussed a draft letter to the CAT Plan Participants and FINRA CAT requesting postponement of the planned changes to the CAIS compliance rate calculations pending the SEC’s decision on the rule filing by the CAT Plan Participants relating to the removal of PII from CAT. The Working Groups discussed comments from an FIF member relating to the removal of PII from CAT.
- CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed the pass-through of CAT fees by FINRA. The Working Group discussed Error Code 2260 (Missing or Invalid BFMM Flag). The Working Group discussed the applicability of the BFMM flag to block positioning activity. The Working Group discussed CAT reporting of verbal quoting activity. The Working Group discussed a draft letter to the CAT Plan Participants and FINRA CAT relating to pre-IPO orders. Working Group members provided an update to the Working Group on a discussion with the CAT Plan Participants and FINRA CAT relating to CAT reporting for route modifications.
Eduard Kotlyar