19 August, 2024
Working Group Updates 8/19/2024
19 August, 2024
- FIF OFR Repo Reporting Working Group. The OFR Repo Reporting Working Group continued its discussion of implementation of the new regulatory requirement to report non-centrally clearing bilateral repos to the OFR. The Working Group discussed calculating the Current cash amount and Securities value and reporting the Security identifier field. The Working Group continued its review of a draft supplemental letter to the OFR, including calculating outstanding commitment amounts, the definition of business day, and reporting for a scenario involving modifications and terminations on the same business day.
- FIF Rule 606 Working Group. The Rule 606 Working Group discussed reporting fees and rebates for options and how to handle the pass-through of CAT fees. The Working Group continued its review and discussion of a draft letter to the SEC requesting guidance on how to calculate the percentage of orders routed to different venues.
- FIF Short Sales / Reg SHO / Short Reporting Working Group. The Working Group discussed how to calculate the net change in gross short position. The Working Group discussed reporting the FIGI identifier. The Working Group completed its update on the July 15 FIF member call with SEC representatives. The Working Group discussed how firms should define “investment discretion”, “control” and “account” for Form SHO reporting.
- FIF SLATE Working Group. The SLATE Working Group discussed a scenario involving multiple lenders. The Working Group reviewed data elements in the FINRA rule filing for SLATE that are not included in SEC Rule 10c-1a. The Working Group continued its review and discussion of a draft FIF comment letter on the FINRA Rule filing and Participant Specification for SLATE, including reporting for transactions that involve a variable fee or rebate.
- Treasury Clearing. Ignacio Sandoval of the Orrick law firm reviewed the current status of the various rule filings by the Fixed Income Clearing Corporation (FICC) to implement the SEC mandates relating to centralized clearing of cash trades in Treasuries and Treasury repos.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group completed its review of the July 24 updates to the CAT Technical Specifications. The Working Group discussed CAT Fee Alert 2024-2. The Working Group reviewed the May 21 updates to the CAT Billing Scenarios. The Working Group discussed FINRA Regulatory Notice 20-31, “FINRA Reminds Firms of Their Supervisory Responsibilities Relating to CAT.”
Eduard Kotlyar