25 November, 2024
Working Group Updates 11/25/2024
25 November, 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 15 call with SEC representatives relating to the calculation of Form SHO reportable amounts. The Working Group discussed next steps on this issue, including the submission by FIF of updated reporting scenarios. FIF submitted these updated scenarios to the SEC. On November 22 FIF members participated on a follow-up call with representatives from the SEC’s Division of Trading and Markets and Division of Economic and Risk Analysis to continue discussion of the calculation of Form SHO reportable amounts.
- OFR Repo Reporting Working Group. The OFR Repo Reporting Working Group discussed reporting of pledges, the requirement to contact the OFR prior to submitting corrections, covered reporter processes when they identify issues through internal validations, privacy law issues, and how to report the Securities Value field on the repo maturity date. The Working Group commenced a review of the new FAQs and FAQ updates published by the OFR on November 14, including FAQs relating to tri-party repos, Category 2 covered reporters, the calculation of outstanding commitments, file size restrictions, OFR validations, and reporting by a third-party vendor.
- TRACE Working Group. The TRACE Working Group reviewed and made edits to a draft FIF letter to FINRA, the MSRB and the Federal Reserve Board (the FRB) on the recent rule changes to require one-minute reporting to TRACE and RTRS, subject to exceptions for certain manual activity and trading by firms with limited trading activity. FIF submitted this letter to FINRA, the MSRB and the FRB. The Working Group reviewed a recent rule change by the FRB to apply to covered depository institutions certain TRACE reporting changes for Treasury securities that are currently applicable to FINRA members.
- Rule 606 Working Group. The Rule 606 Working Group reviewed and made edits to a revised draft FIF letter to the SEC in response to verbal guidance from the SEC on how to calculate the percentage of orders routed to different venues for Rule 606(a) reporting.
- 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 CAIS Working Group. The CAIS Working Group discussed updates to FAQ Q19 relating to FDID Refresh Reports. The Working Group discussed feedback from FINRA CAT relating to a request by FIF members for FINRA CAT to include the repair due date for errors, the scenario where a member ends a record that should not have been submitted to CAIS and the record has a Material Inconsistency, CAIS portal timeouts, and the accountHolderType instructions in the CAT Transaction Reporting specifications. The Working Group discussed various challenges with logging in to the CAIS portal.
- 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 representative order linkage for options and OTC Link. The Working Group discussed reporting the NAV handling instruction, reporting for a flex option scenario, and the interest rate calculation for CAT billing. The Working Group reviewed a recent update to the CAT Billing Scenarios document relating to an options floor trading scenario. The second Working Group call focused on the reporting by a routing firm of default settings applied by an exchange, ATS or receiving broker.
Eduard Kotlyar