09 December, 2024
Working Group Updates 12/9/2024
09 December, 2024
- Short Position Reporting; Reg SHO. The FIF Short Sales / Reg SHO / Short Reporting Working Group continued its discussion of the implementation of short position reporting. FIF members provided an update to the Working Group on a December 2 call with representatives from the SEC’s Division of Trading and Markets and Division of Economic and Risk Analysis relating to the calculation of Form SHO reportable amounts. The Working Group discussed a Form SHO reporting scenario where an account changes from negative to positive. The Working Group discussed the most recent updates to the Form SHO Technical Specification. The Working Group discussed a question from an FIF member relating to the exception from the locate requirement for bona-fide market making activity.
- OFR Repo Reporting Working Group. FIF hosted two calls this past week for the OFR Repo Reporting Working Group. The Working Group discussed reporting for repos with central bank counter-parties. The Working Group discussed the OFR’s validation when a covered reporter reports a value of 0 for certain fields. The Working Group completed its discussion of the OFR’s FAQ updates published on November 14, including reporting for forward-start repos and repos that have multiple types of collateral. The Working Group discussed a draft FIF letter to the OFR relating to the current reporting status, the process for submitting corrections, and reporting the Securities Quantity. The Working Group discussed responding to exceptions identified by the OFR’s DCU group. The Working Group discussed feedback from the OFR on production filings. The Working Group discussed reporting controls implemented by covered reporters.
- Regulation NMS Amendments. FIF hosted a call for the SEC Equity Market Proposals Working Group to continue the discussion of the implementation of the SEC’s amendments to Regulation NMS. The Working Group discussed calculation of the TWAQS (Time Weighted Average Quoted Spread) for stocks that trade above and below $1, stocks that are subject to a trading halt and stocks that have crossed and locked markets. The Working Group discussed determination of the minimum price increment for newly-listed stocks and stocks that are subject to a merger, stock split or other corporate event.
- CAT Monthly Update Working Group. 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.
- CAT Transaction Reporting Working Group. FIF hosted two calls this past week for the CAT Transaction Reporting Working Group. During the first call, the Working Group discussed Rule 10b-10 disclosure for the pass-through of CAT fees. The Working Group reviewed a draft FIF comment letter on the rule filing by the CAT Plan Participants to reduce CAT operating costs. FIF submitted this comment letter to the SEC. The Working Group reviewed a draft FIF comment letter on a rule filing by the CAT Plan Participants to permanently exempt certain pre-order communications from CAT reporting. FIF submitted this comment letter to the SEC. The Working Group discussed the correction of issues that are outside the books and records timeframe. The Working Group discussed reporting for options error scenarios. The second Working Group call focused on CAT reporting by a routing firm of default settings applied by a receiving firm.
Eduard Kotlyar