10 June, 2024
Working Group Update 6/10/2024
10 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 the documentation published by the Treasury Department’s Office of Financial Research (OFR) relating to reporting for repos that are executed bilaterally and not centrally-cleared (NCCBR repos). The Working Group reviewed and discussed a draft FIF letter to the OFR requesting clarification on various issues and questions relating to the implementation of this new reporting requirement.
- 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 for orders executed after 9:30 but prior to the opening cross, reporting for GTC orders, and reporting for pegged and other order types with different characteristics.
- SEC Rule on Short Position and Short Activity Reporting. The FIF Short Sales / Reg SHO / Short Reporting Working Group discussed comments and questions from FIF members relating to the implementation of SEC Rule 13f-2. Rule 13f-2 requires the reporting of certain gross short positions and daily net changes in positions. 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.
- FIF Securities Lending Transparency Working Group. Ignacio Sandoval of the Orrick law firm completed a review of the FINRA rule filing for the SLATE reporting system. The Working Group commenced a review and discussion of the Participant Specification for SLATE recently published by FINRA.
- Residential Supervisory Locations. FIF hosted a sub-group call to discuss questions from FIF members in response to recent guidance published by FINRA and recent webinars hosted by FINRA relating to residential supervisory locations and the remote inspections pilot.
- FIF CAT Monthly Update Working Group. The Working Group reviewed guidance and updates from the CAT Plan Participants and FINRA CAT on CAT Transaction Reporting, CAT CAIS and CAT billing reporting during the prior month. The Working Group 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 CAIS Working Group. The CAIS Working Group reviewed a draft submission to FINRA CAT relating to the scenario where a reporting firm engages multiple submitting firms to report on its behalf. FIF submitted this comment to FINRA CAT. The Working Group reviewed a letter previously submitted by FIF to the SEC and the CAT Plan Participants relating to the retirement of Electronic Blue Sheets (EBS) for equities and options. The Working Group discussed next steps. FIF contacted the SEC and FINRA to request a call to discuss the retirement of EBS.
- 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 to customer orders and linkage of order fulfillments to representative and principal orders. During the second call, the Working Group discussed the plan by the CAT Plan Participants and FINRA CAT to make the reporting of NIA RFQ responses to CAT optional as of July 31, 2024. The Working Group also reviewed the March 2024 updates to the CAT Technical Specifications document.
Eduard Kotlyar