04 November, 2024
Working Group Updates 11/4/2024
04 November, 2024
- Short Position Reporting. FIF hosted three 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. During the first call, Working Group members provided an update on a call with the SEC staff on October 24. The Working Group continued its discussion of current implementation challenges, including reporting for convertible bonds. During the second call, the Working Group discussed engagement of vendors, the product scope for short position reporting, reporting the issuer LEI, and reporting for multiple affiliated entities. During the third call, the Working Group reviewed a draft FIF letter to the SEC providing comments on the SEC’s draft technical documentation. The Working Group also discussed test file submissions, reporting for convertible bonds, and reporting for Section 15(d) reporting issuers.
- OFR Repo Reporting Working Group. The OFR Repo Reporting Working Group discussed issues and questions raised by FIF members relating to the implementation of the new requirement to report non-centrally cleared bilateral repos to the Treasury Department’s Office of Financial Research. The Working Group discussed the OFR feedback process. The Working Group reviewed and discussed a redline of the OFR’s changes to the Reporting Instructions document.
- TRACE Working Group. The TRACE Working Group continued its discussion of the recent FINRA and MSRB amendments to reduce the reporting timelines for TRACE and RTRS, subject to certain exceptions. The Working Group discussed various trading and reporting scenarios and whether the manual trade indicator would apply to these scenarios. The Working Group reviewed a revised draft of an FIF letter to FINRA and the MSRB with comments and questions relating to the implementation of the reporting changes. The Working Group discussed the testing process, a request for FINRA and the MSRB to allow firms to optionally report the manual trade indicator to TRACE for other bonds, and whether the rule changes apply to covered depository institutions.
- NSCC Rule Change on Fractional Share Trading. FIF hosted a call for the Front Office and Back Office Committees to discuss the recent NSCC rule change on fractional share trading.
- 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. The spotlight presenter was Steve Dickey from OPRA, who discussed the OPRA Multicast Dynamic Rebalance Plan. Please find the meeting materials here and the full capacity stats here.
- Tax Information Reporting Working Group. Stevie Conlon, Anna Vayser and Robert Schwaba from Wolters Kluwer discussed key differences between digital asset and securities broker tax reporting.
- 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 the FIF exemption request relating to representative order linkage. During the second call, the Working Group discussed the CAT system validation of an FDID when an industry member submits a historical CAT Transaction Reporting event, reporting the BFMM flag, reporting for events that occur after an early close, error rates for weekend and holiday submissions, a request for FINRA CAT to make available a single portal log-in for a user associated to multiple broker-dealers, removing Error Code 897 (early reported event), and splitting the TRF and exchange billing records into separate billing files. The Working Group reviewed the recent updates to the CAT billing Technical Specifications and the CAT Transaction Reporting Technical Specifications.
Eduard Kotlyar