03 June, 2024
Working Group Update 6/3/2024
03 June, 2024
- FIF 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 discussed comments from an FIF member relating to the implementation timetable for this new reporting requirement.
- 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 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 the implementation timetable, formatting for the detailed and summary reports, reporting for notional value orders, and required updates to the current Rule 605 FAQs.
- FIF Rule 606 Working Group; FINRA Rule 6151. The FIF Rule 606 Working Group reviewed and discussed updated documentation and guidance from FINRA relating to FINRA Rule 6151 (centralized reporting of Rule 606(a) reports), including FAQs published by FINRA and updates to the FINRA Rule 6151 Order Routing Information Filing Guide. The Working Group discussed the required time period for providing data pursuant to SEC Rule 606(b)(3) in response to a customer request.
- FIF Data and Technology Committee. The Data and Technology Committee reviewed capacity, latency and volume data for the prior month for the equity, options, currency, crypto and futures markets. The spotlight presenter was John Hiatt of Cboe Labs, who discussed the Cboe Dispersion Index. Please find the meeting materials here and the full capacity report here.
- FIF Front Office Committee. The Front Office Committee reviewed applicable updates and notices from the SEC, FINRA, FINRA CAT and the equity and option exchanges. Please find the meeting agenda here.
- FIF CAIS Working Group. The CAIS Working Group reviewed a draft submission to FINRA CAT on a proposal to simplify the process for ending an FDID. The Working Group discussed the scenario where multiple clearing firms report to CAIS on behalf of the same introducing firm and the CAIS system generates an inter-firm inconsistency based on the records of the different clearing firms. The Working Group discussed the next steps to achieve retirement of electronic blue sheets reporting. The Working Group discussed report cards for inconsistencies. The Working Group discussed the FINRA rapid remediation process as applied to CAIS.
- 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 May 22, 2024 incident where certain option symbols were not included in the end-of-day CAT security master file. The Working Group also continued its review and discussion of FIF member suggestions relating to file generation, error management and the CAT Transaction Reporting portal. The Working Group discussed a proposal from FINRA CAT representatives to facilitate reconciliation of the executed equivalent shares amount between the monthly CAT invoice and the CAT billing trade details file. The Working Group reviewed the March 28 updates to the CAT Transaction Reporting Technical Specifications.
Eduard Kotlyar