02 December, 2024
Working Group Updates 12/2/2024
02 December, 2024
- Short Position Reporting. 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 November 22 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 reporting requirements relating to LEIs, CUSIPs and FIGIs, calculating whether a firm meets Threshold A for a security, and how settlement dates should be defined. The Working Group discussed next steps with the SEC.
- Securities Lending Transparency Working Group. The Securities Lending Transparency Working Group discussed the recent FINRA rule filing for SLATE fees. The Working Group discussed Partial Amendment No. 1 for SLATE recently filed by FINRA. The next step for the Working Group will be to review and discuss the revised Participant Specification when it is published by FINRA.
- OFR Repo Reporting Working Group. The OFR Repo Reporting Working Group discussed sending a letter to the OFR to request a conformance period for NCCBR repo reporting. Working Group members updated the Working Group on their respective discussions with the OFR relating to corrections, validations and the upcoming live date for reporting. The Working Group discussed reporting of corrections. The Working Group discussed reporting for a scenario where additional collateral is submitted for a portfolio of loans. The Working Group discussed points that FIF members want FIF to raise on an upcoming call with the OFR. The Working Group continued its discussion of the new FAQs published by the OFR on November 15.
- Data and Technology Committee. The Data and Technology Committee reviewed capacity, latency and volume data for the prior month for the equity, options, currency, crypto and futures markets. Please find the meeting materials here and the full capacity statistics here.
- CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed an update from FINRA CAT on separating the CAT Billing Trade Details files into separate files for TRF and exchange records. The Working Group discussed CAT Fee Alert 2024-3. The Working Group discussed a scenario where a customer sends a long sale that the broker-dealer determines to be a short sale. The Working Group discussed the Order Instituting Proceedings published by the SEC on November 18 relating to the proposed CAT amendment to exempt reporting of verbal activity. The Working Group discussed the CAT cost estimates for 2025 published by FINRA CAT on November 20. The Working Group continued the review of feedback from FINRA CAT relating to early close scenarios, error rates for weekend and holiday submissions, the timeout period for the CAT portal, adding the ability for users to filter on the portal by CRD number, download file names, and the exchOriginCode in option route modification events.
Eduard Kotlyar