28 May, 2024
Working Group Update 5/28/2024
28 May, 2024
- OFR Repo Reporting Working Group. The Working Group reviewed and discussed 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).
- SEC Rule on Short Position and Short Activity Reporting. The FIF Short Sales / Reg SHO / Short Reporting Working Group continued its review and discussion of a draft FIF letter to the SEC on implementation issues relating to 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 discussion of the jurisdictional scope of Rule 13f-2 reporting.
- 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 comments and questions from FIF members relating to reporting for an order that is partially executed pre-market or during an auction, reporting for the scenario where the tick test comes into effect after order receipt, reporting for a straddle state, and reporting metrics against the best odd lot price if the best odd lot quotes are crossed.
- FIF Cybersecurity Working Group. Matt Weinberg of the Cybersecurity and Infrastructure Agenda (CISA) provided an update on current threats to the financial industry. CISA is an agency of the US Department of Homeland Security. The Working Group also reviewed recent FINRA, DTCC and NSA updates relating to cybersecurity.
- 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 the meeting materials here.
- FIF CAIS Working Group. The CAIS Working Group discussed reporting accounts for employees participating in a corporate stock plan, how the monthly CAIS report cards will handle prior month Material Inconsistencies, and feedback from FINRA CAT on FIF member requests relating to the outstanding rejections feedback file, querying for FDID status and ending a CAIS FDID.
- 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 reviewed and discussed 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 exemptive order issued by the SEC on May 20 relating to the reporting of RFQ responses that are not immediately actionable. The Working Group also discussed continuing challenges with reporting pre-IPO orders, splitting the TRF and exchange records into separate billing trade details files, issues with the updated CAT report cards, reporting the RLO (Retail Liquidity Order) handlingInstructions value, proposed enhancements to the CAT Transaction Reporting portal, and FIF member suggestions relating to file generation and error management.
Eduard Kotlyar