21 October, 2024
Working Group Updates 10/21/2024
21 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 the Minimum Maturity Date for open repos, reporting for a scenario where a parent Category 2 covered reporter guarantees the obligations of a subsidiary Category 1 covered reporter, the impact of margin on the Current Cash Amount, reporting repos on the end date, and the scenario where a repo does not settle on the end date.
- TRACE Working Group. The 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.
- Short Position Reporting. The Short Sales / Reg SHO / Short Reporting Working Group continued its discussion of the implementation of short position reporting. The Working Group discussed next steps with the SEC, including coordination with other industry associations. The Working Group discussed issues and questions from FIF members relating to reporting for error accounts, reporting for firm accounts, and reporting when a single CUSIP has multiple exchange listings.
- Financial Data Transparency Act Working Group. FIF hosted two calls this past week for the Financial Data Transparency Act (FDTA) Working Group. The Working Group reviewed and provided comments on a draft FIF comment letter on the Notice of Proposed Rulemaking by the SEC and other financial regulators to implement certain requirements of the FDTA.
- Digital Asset Securities Working Group. Shawn Sloves of Fundamental Interactions led a discussion on the special purpose broker-dealer license and settlement and custody issues.
- Back Office Committee. The Back Office Committee reviewed applicable FICC, DTC, NSCC, SEC, MSRB, OCC, IRS and FINRA updates during the past month. Please find the meeting agenda here.
- CAT CAIS Working Group. The CAIS Working Group discussed a scenario resulting in FDID validation errors. The Working Group discussed challenges with using DTCC ALERT data for CAIS reporting. The Working Group discussed Material Inconsistencies for a scenario where a firm ends a CAIS record that the firm was not required to submit. The Working Group reviewed the results of the FIF member survey on the volume of EBS requests.
- CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed a follow-up request from FINRA relating to the FIF exemption request for representative order linkage. The Working Group discussed the Nasdaq Price Slide port setting, creating an industry standard for CAT rebilling by broker-dealers, CAT rebilling by FINRA, and a scenario where the leaves quantity falls below the minimum quantity after a partial execution. The Working Group discussed the responses from FINRA CAT to prior comments and questions submitted by FIF.
Eduard Kotlyar