13 January, 2025
Working Group Updates 1/13/2025
13 January, 2025
- Short Position Reporting. FIF hosted two calls this past week on short position reporting. During the first call, FIF members updated the Working Group on a call with SEC Commissioner Peirce relating to the implementation of short position reporting. The Working Group also discussed the inability to submit XML tables through the EDGAR web portal, technical challenges with submitting test files to EDGAR, reporting for a position that is short vs. the box, reporting for securities that do not have a CUSIP or other identifier, and which version of FIGI to report. During the second call, the Working Group discussed reporting when a security has a mid-month CUSIP changes, EDGAR CIKs, and reporting for January 9. The Working Group also discussed a draft FIF letter to the SEC relating to netting of short positions with long positions.
- OFR Repo Reporting Working Group. The OFR Repo Reporting Working Group discussed reporting for an intra-day or overnight repo traded by a foreign branch that starts on a US holiday. The Working Group discussed reporting for a repo that is cancelled after the start date. The Working Group reviewed the December 17 FAQ updates published by the OFR.
- CAT Transaction Reporting Working Group. The CAT Transaction Reporting discussed the current status on representative order linkage. The Working Group discussed recent CAT fee filings and the expected monthly CAT fees for 2025. The Working Group discussed reporting timestamps that are finer than nanoseconds. The Working Group discussed a January 7 response by FINRA to a letter submitted by FIF to FINRA on December 20 relating to reporting when there is an early-close and reporting rep order linkage for options. FIF members provided an update to the Working Group on a December 20 call with FINRA CAT representatives relating to removing Error Code 897 (warning for early reported event) and FINRA CAT providing machine-readable invoices. The Working Group discussed a recent change implemented by FINRA CAT to reject Rule 144A securities, thereby eliminating named errors to counter-parties for these securities.
Eduard Kotlyar