15 July, 2024
Working Group Update 7/15/2024
15 July, 2024
- OFR Repo Reporting Working Group. FIF hosted two calls this past week for the OFR Repo Reporting Working Group. The Working Group continued its discussion of the implementation of the rule adopted by the Treasury Department’s Office of Financial Research to require reporting of non-centrally cleared bilateral repos. The Working Group discussed the scenarios where a repo has multiple types of transferred securities and where securities are transferred as a pool to support a portfolio of related repos. The Working Group reviewed and discussed a draft FIF letter to the OFR.
- FIF Securities Lending Transparency Working Group. The Securities Lending Transparency Working Group continued its review and discussion of the SLATE Participant Specification published by FINRA. The Working Group discussed various issues and questions from FIF members relating to the SLATE reporting requirements, including reporting for cross-border scenarios and reporting for modifications on the date that a loan transaction is agreed.
- FIF Short Sales / Reg SHO / Short Reporting Working Group. The Working Group discussed clarification requests from the SEC in response to the letter submitted by FIF on June 24 relating to the requirement to report gross short positions where the reporting firm exceeds specified thresholds.
- FIF CAT Monthly Update Working Group. The CAT Monthly Update Working Group reviewed guidance and updates from the CAT Plan Participants and FINRA CAT on CAT Transaction Reporting, CAT CAIS and CAT billing during the prior month. The Working Group also reviewed the current areas of focus for FIF members and the current open issues for CAT Transaction Reporting, CAT CAIS reporting and CAT billing.
- FIF CAT CAIS Working Group. The CAIS Working Group reviewed a draft submission by FIF to FINRA CAT relating to scenarios where a reporting firm updates the foreignTIDType for a CAT Customer and either the same reporting firm or another reporting firm submits a record to CAT on the same day for the same CAT Customer. The Working Group discussed proposed summary data relating to Electronic Blue Sheets to be provided by FIF members to track the ongoing level of EBS requests from regulators. The Working Group continued its discussion of cascading CAIS errors.
- FIF CAT Transaction Reporting Working Group. An FIF member reviewed with the Working Group a presentation on the reporting of auction-related handling instructions. The Working Group discussed the scenarios in this presentation and next steps to obtain guidance from FINRA CAT. The Working Group discussed the correction of reporting issues that arose outside the books and records timeline (i.e., more than three years prior). The Working Group discussed the change by FINRA CAT to determine errors based on the initial processing date for a record as opposed to the event date. The Working Group discussed CAT reporting for options correction scenarios.
Eduard Kotlyar