17 June, 2024
Working Group Update 6/17/2024
17 June, 2024
- FIF OFR Repo Reporting Working Group. FIF hosted two calls this past week for the OFR Repo Reporting Working Group. The Working Group continued its review and discussion of a draft FIF letter to the Treasury Department’s Office of Financial Research (OFR) requesting clarification on various issues and questions relating to the new requirement to report repos that are executed bilaterally and not centrally-cleared (NCCBR repos).
- FIF Rule 605 Working Group. The Rule 605 Working Group continued its review of a draft FIF comment letter to the SEC relating to implementation of the changes to Rule 605 that the SEC adopted on March 6. The Working Group discussed reporting the time of order receipt, reporting when odd-lot quotes are added to the SIP, reporting the Order Type categories, and reporting for GTC orders.
- FIF Short Sales / Reg SHO / Short Position Reporting Working Group. FIF hosted two calls this past week for the Short Sales / Reg SHO / Short Reporting Working Group. The Working Group continued its review and discussion of a draft FIF letter to the SEC on implementation issues relating to SEC Rule 13f-2 (Short Position and Short Activity Reporting) and the associated Form SHO. Rule 13f-2 requires the reporting of certain gross short positions and daily net changes in positions. FIF submitted this comment letter to the SEC on June 14.
- FIF Securities Lending Transparency Working Group. The Securities Lending Transparency Working Group reviewed and discussed the Participant Specification for SLATE recently published by FINRA.
- FIF CAIS Working Group. The CAIS Working Group discussed issues for FIF to revisit with FINRA CAT now that the compliance date for Full CAIS has passed. The Working Group discussed cascading errors generated by the CAIS system, a recommendation to add the FDID to feedback files, the scenario where multiple clearing firms clear and do CAIS submissions for the same correspondent firm, formatting issues with extracting rejections from CAIS into Excel, and various scenarios where the CAIS system is mistakenly generating errors or inconsistencies. FIF members participated on a call with SEC representatives to discuss the retirement of duplicate reporting requirements, including EBS for equities and options and large trader identification requirements.
- FIF CAT Transaction Reporting Working Group. FIF hosted two calls this past week for the CAT Transaction Reporting Working Group. During the first call, the Working Group continued its review and discussion of a draft FIF exemptive request letter on linkage of representative orders and quotes to customer orders and linkage of order fulfillments to representative and principal orders and quotes. During the second call, the Working Group discussed changing the exchOriginCode in route reports to optional, adding the accountHolderType field to New Order Supplement events, and handlingInstructions values for Order Route events. The Working Group also reviewed the April 12 updates to the CAT Transaction Reporting scenarios document.
Eduard Kotlyar