28 October, 2024
Working Group Updates 10/28/2024
28 October, 2024
- 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 reporting for clients that do not have an LEI, the current validation that the Floating Rate Reset Frequency must be positive, the definition of the Haircut data element, and feedback from the OFR on test files. The Working Group reviewed and made final edits to a letter to the OFR that addresses corrections, reporting repos on the end date, reporting for the scenario where the closing leg does not settle on the agreed settlement date, and error feedback.
- Short Position Reporting. FIF hosted two calls this 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, the Working Group discussed the draft technical documentation published by the SEC, including the draft XML Technical Specification. The Working Group also discussed current implementation challenges, including reporting for convertible bonds and ETFs. During the second call, a representative from ICE Data Services discussed an ICE data product for Form SHO reporting. FIF provided an update on a call with advisors to SEC Chair Gensler on October 23. The Working Group continued its discussion of reporting for convertible bonds and other derivative securities.
- Rule 606 Working Group. The Rule 606 Working Group discussed next steps in response to feedback from the SEC relating to Rule 606(a) reporting of the percentage of orders routed to different venues.
- Rule 605 Working Group. The Rule 605 Working Group discussed responses from the SEC to the June 2024 FIF letter relating to the implementation of the Rule 605 amendments. The Working Group discussed the oversight obligation of introducing brokers, reporting for verbal order scenarios, reporting for complex option orders, and reporting for securities where the round lot size is 1.
- Reg NMS Amendments. FIF hosted a call for the Equity Market Proposals Working Group to continue the discussion of the SEC’s recent amendments to Regulation NMS.
- Section 31 Fee Reconciliation. The FIF Section 31 Fee Reconciliation subgroup discussed a file being made available by FINRA since June 2024 to assist firms in reconciling their Section 31 invoices.
- Front Office Committee. The Front Office Committee reviewed applicable updates and notices from the SEC, FINRA, FINRA CAT and the equity and option exchanges. The agenda can be found here.
- CAT Transaction Reporting Working Group. The Working Group discussed CAT reporting for the scenario where a dealer fills or stops a customer ETF order. The Working Group discussed reporting of the BFMM flag. FIF members provided an update on an October 21 discussion with SEC Chair Gensler’s advisors relating to representative order linkage. The Working Group discussed a draft FIF comment letter on a rule filing by the CAT Plan Participants to reduce CAT operating costs. The Working Group reviewed and discussed recently-published FAQs relating to CAT billing.
Eduard Kotlyar