10 February, 2025
Working Group Updates 2/10/25
10 February, 2025
- Short Position Reporting. The FIF Short Sales / Reg SHO / Short Position Reporting Working Group continued its discussion of the implementation of short position reporting. The Working Group discussed identifying Threshold A and Threshold B securities, the January 30 updates to the Form SHO Technical Specifications, a rejection received by a firm when reporting two securities with the same issuer and class name and different CUSIPs, reporting for January 9, and the jurisdictional scope of reporting.
- Rule 605 Working Group. The Rule 605 Working Group continued its discussion of the implementation of the SEC’s amendments to Rule 605. The Working Group discussed next steps given that the SEC has not yet published technical specifications or provided interpretive guidance for Rule 605 implementation. The Working Group discussed FIF coordinating a template disclosure for retail investors relating to the Rule 605 summary reporting.
- SEC Rule 606 and FINRA Rule 6470 Working Group. The SEC Rule 606 and FINRA Rule 6470 Working Group continued its discussion of OTC Link reporting scenarios for Rule 6470, including the potential impact of guidance from FINRA examiners for Rule 606(a) reporting when an order is routed to multiple venues. The Working Group discussed other issues raised by FIF in its September 2023 FIF letter to FINRA that remain open.
- SLATE Working Group. The SLATE Working Group continued its discussion of the implementation of SLATE reporting. The Working Group discussed the likelihood of delay in SLATE implementation, reporting for fully-paid lending, the requirement to obtain a new issue identifier, and reporting for loans by the New York Fed. The Working Group discussed open interpretive issues relating to SLATE reporting.
- CAT Monthly Update Working Group Call. The CAT Monthly Update Working Group reviewed guidance and updates from the CAT Plan Participants and FINRA CAT on CAT Transaction Reporting, CAT CAIS and CAT billing during the prior month. The Working Group reviewed the current areas of focus for FIF members and the current open issues for CAT Transaction Reporting, CAT CAIS reporting and CAT billing. The Working Group continued its discussion of the recent blog by Robert Cook, President and CEO of FINRA CAT, relating to the removal of personal data from CAT.
Eduard Kotlyar