11 November, 2024
Working Group Updates 11/11/2024
11 November, 2024
- 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 reviewed and made final edits to a supplemental letter to the SEC. FIF submitted this letter to the SEC. The Working Group reviewed a draft request to the SEC for an extension of the compliance date for Form SHO reporting. FIF submitted this extension request to the SEC. The Working Group discussed a summary of the October 24 FIF member call with the SEC. The Working Group discussed proposed wording for the EDGAR site. FIF sent a survey to Working Group members on short position reporting for a firm with multiple principal accounts.
- OFR Repo Reporting Working Group. The OFR Repo Reporting Working Group discussed issues and questions raised by FIF members relating to OFR validations, feedback from the OFR on test files and reporting for corporate actions. The Working Group discussed the September 25 updates to the Reporting Instructions and Technical Guidance documents. The Working Group reviewed a revised draft letter to the OFR on reporting lender and borrower identifiers, reporting rates based on 360 or 365 days, and data validations for open variable trades. The Working Group continued its discussion of an outline of issues discussed by the FIF Working Group.
- Rule 606 Working Group; FINRA Rule 6470. The Rule 606 Working Group discussed a draft 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. The Working Group discussed a request for feedback from FINRA CAT on the implementation of FINRA Rule 6470 (OTC routing reports).
- Rule 605 Working Group. The Rule 605 Working Group discussed Rule 605 reporting for GTC orders, mid-peg orders and discretionary and slide orders. Working Group members provided an update on a call with the Rule 605 NMS Plan Committee. The Working Group discussed reporting the symbol on the Rule 605 report and reporting order size and order type category labels.
- 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. The CAT Transaction Reporting Working Group discussed feedback from the SEC on CAT reporting of port settings by a routing firm. The Working Group discussed next steps on port settings. The Working Group discussed a draft FIF temporary exemption request on representative order linkage. FIF submitted the draft exemption request to the SEC. The Working Group discussed representative order linkage for options.
Eduard Kotlyar