12 August, 2024
Working Group Updates 8/12/2024
12 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 threshold for Category 1 Covered Reporters, reporting for allocations, reporting for same-day cancels, reporting the trade timestamp, and reporting the state and end dates.
- FIF Short Sales / Reg SHO / Short Reporting Working Group. This past week, FIF hosted two calls for this Working Group to continue discussing the implementation of the SEC’s Rule 13f-2 and Form SHO reporting. During both calls, the Working Group continued its review and discussion of a draft follow-up FIF letter to the SEC relating to the implementation of Rule 13f-2 reporting. The letter requests guidance on how to calculate the gross short position for various scenarios, requests confirmation of previous guidance provided by the SEC, requests additional guidance relating to Form SHO reporting, requests that the SEC publish written FAQs relating to Form SHO reporting, and recommends various steps for the SEC to take, including a delay in the implementation date and relief from calculating shares outstanding based on the current Form SHO instructions. FIF submitted the follow-up letter to the SEC on August 9.
- FIF SLATE Working Group. 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 the following topics: the daily filing deadline; reporting for variable rate loans; reporting loan terminations; reporting corrections; and reporting the time that a covered reporter records a loan in its books and records.
- FIF CAT CAIS Working Group. The Working Group continued its discussion of the following recommendations by FIF members: the CAIS feedback providing the CRD number for Material Inconsistencies where multiple submitting firms submit for a single reporting firm; the CAIS feedback including FDIDs in the daily Outstanding Material Inconsistencies file without a cap on the number of FDIDs; the CAIS feedback including FDIDs for Customer rejections; and recommendations to address cascading errors generated by the CAIS system. FIF submitted these recommendations to FINRA CAT.
- FIF CAT Transaction Reporting Working Group. The Working Group reviewed the SEC’s recent Notice Of Designation relating to the CAT fee filings. The Working Group reviewed CAT Fee Alert 2024-1 and the updates to CAT Alert 2023-02 relating to CAT billing. The Working Group discussed CAT reporting for market orders. The Working Group discussed the CAT file formats (JSON and CSV), review tools for files provided by third-parties, and tools to convert between JSON and CSV formats. The Working Group reviewed and discussed the July 24 updates to the CAT Technical Specifications.
Eduard Kotlyar