18 November, 2024
Working Group Updates 11/18/2024
18 November, 2024
- Back Office Committee. The Back Office Committee reviewed applicable FICC, DTC, NSCC, SEC, MSRB, OCC, IRS and FINRA updates during the past month. The spotlight presenter was Sheila Zak of the Options Clearing Corporation, who provided an update on external testing for OCC Ovation. Please find this month's agenda here.
- CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed whether to include CAT fees in EBS reporting, the auction handling instructions, reporting for order and route modifications and linkage for OTC Link order fulfillments. The Working Group reviewed new FAQs published by FINRA CAT on the CAT Fee Dispute Resolution process. The Working Group reviewed recent updates to the Reporting Scenarios published by FINRA CAT. The Working Group discussed feedback from FINRA CAT on reporting the BMLL handling instructions value.
- LOPR Working Group. The Large Options Positions Reporting (LOPR) Working Group discussed current practices applied by reporting firms to identify In Concert groups for LOPR reporting.
- OFR Repo Reporting Working Group. The OFR Repo Reporting Working Group discussed reporting for the scenario where the start date precedes the trade timestamp. The Working Group discussed reporting for forward-start repos where the securities value at inception is not known prior to the start date. The Working Group discussed reporting the securities quantity for securities that are traded based on notional value. The Working Group continued its review of an outline of issues previously discussed by the Working Group.
- Reconciliation of Section 31 Fees. The Section 31 subgroup continued its discussion of a recent pilot by FINRA to provide trade-level details to support reconciliation of Section 31 fees. The Working Group discussed next steps, including proposing to FINRA that the fields for the file be expanded to include additional TRF reporting fields and proposing that FINRA also make the file available to non-clearing executing broker-dealers.
- Rule 605 Working Group. The Rule 605 Working Group discussed the November 12 FIF member call with the SEC on the implementation of Rule 605 reporting. The Working Group discussed challenges with reporting stop orders where the triggering of the stop order occurs at a downstream broker-dealer, reporting for GTC orders, and determining the shares executed regular way at prices that could have filled the order while the order was in effect. The Working Group continued its discussion of the October 31 FIF member call with the Rule 605 NMS Plan Committee on the file format for the detailed Rule 605 report.
- Short Position Reporting. FIF hosted two calls this past week for the Short Sales / Reg SHO / Short Reporting Working Group to continue the discussion of the implementation of short position reporting. The Working Group discussed responses from FIF members to the FIF survey on short position reporting. The Working Group discussed draft wording to propose to the SEC for the EDGAR website instructions on how a manager should calculate its gross short position. FIF submitted this draft wording to the SEC. The Working Group discussed an issue with the XML file layout in the SEC’s Technical Specification. FIF submitted a letter to the SEC on this issue. The Working Group discussed reporting for dually-listed securities and reporting for stock splits.
- TRACE and RTRS One Minute Reporting. The TRACE Working Group continued its discussion of the recent approvals by the SEC of the FINRA and MSRB rule filings that provide for one-minute reporting to TRACE and RTRS, subject to exceptions for manual activity and firms with limited trading activity. The Working Group discussed the applicability of the rule changes to covered depository institutions. The Working Group discussed the applicability of the rule changes to firms with limited trading activity. The Working Group discussed a request by FIF members for FINRA and the MSRB to include data on their respective report cards relating to trades that are not reported within one-minute. The Working Group discussed additional scenarios where further guidance is required on whether to report the manual trade indicator. The Working Group reviewed a draft letter to FINRA, the MSRB and the FRB relating to the implementation of one-minute reporting and reporting of the manual trade indicator.
Eduard Kotlyar