29 July, 2024
Working Group Updates 7/29/2024
29 July, 2024
- FIF OFR Repo Reporting Working Group. The OFR Repo Reporting Working Group discussed issues and questions from FIF members relating to Rule 15a-6 transactions, the start date for testing, onboarding for firms with multiple reporting entities, cross-border scenarios involving allocations, cash and position snapshot times, tri-party repos that involve a custodian other than BNY, and reporting the rate field for certain floating rate scenarios.
- 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 the first call, a representative from Bloomberg reviewed a product being developed by Bloomberg to assist firms in identifying Threshold A and B securities and registration status pursuant to Section 12(b), 12(g) and 15(d) of the Exchange Act. During both calls, the Working Group reviewed a draft follow-up FIF letter to the SEC relating to the implementation of short position reporting.
- FIF Securities Lending Transparency Working Group. The Securities Lending Transparency Working Group discussed issues and questions from members relating to the proposed 8 pm cut-off time for SLATE and reporting the required percentage of collateral field to SLATE, reporting loans involve a pool of collateral, reporting terminations, and reporting by lending agents.
- FIF Rule 606 Working Group. The Rule 606 Working Group discussed issues and questions from FIF members relating to Rule 606(a) reporting, including look-through reporting and calculating the percentage of orders routed to different venues.
- FIF Digital Assets Working Group. Shawn Sloves of Fundamental Interactions let a discussion on special purpose broker-dealers (SPBDs), SEC Rule 15c2-11 (dissemination of quotations) and decentralized finance trading. Please find the meeting materials here.
- FIF 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 this months agenda here.
- FIF CAT CAIS Working Group. The CAIS Working Group reviewed the July 18, 2024 updates to the Full CAIS Technical Specifications. The Working Group reviewed the recent updates to the CAIS Industry Member Release Rollout schedule. Working Group members provided an update to the full Working Group on discussions with FINRA CAT representatives relating to: the generation of intra-firm Material Inconsistencies when multiple submitting firms submit for a single reporting firm; simplifying the process for ending an FDID; a request for the CAIS system to provide the due date for each item in the outstanding rejections feedback file; and the CAIS system providing FDIDs for Material Inconsistencies. The Working Group continued its discussion of cascading CAIS errors.
- FIF CAT Transaction Reporting Working Group. The Working Group discussed whether the CAT Transaction Reporting system generates errors when a firm submits historical events and (i) the FDID was active for the event date but is not currently active, or (ii) the FDID was not active for the event date. The Working Group discussed forecasts for various historical and prospective CAT billing rates. The Working Group discussed CAT billing for options. The Working Group discussed CAT reporting for the receipt and route of partial cancels. The Working Group discussed CAT billing and reconciliation.
Eduard Kotlyar