13 May, 2024
Working Group Update 5/13/2024
13 May, 2024
- FINRA Trade Reporting Notice on Fractional Share Transactions. The Data and Technology Committee and the TRF/ORF Working Group reviewed a draft FIF letter to FINRA in response to the March 22 FINRA Trade Reporting Notice on Upcoming Trade Reporting Enhancements for Fractional Share Transactions. The Working Group discussed reporting for corrections and the reporting flag for transactions that are away from the market.
- 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 implementation issues relating to SEC Rule 13f-2 on Short Position and Short Activity Reporting. The Working Group reviewed and discussed the section from the SEC’s reply brief presenting the SEC’s view on the jurisdictional scope of Section 13f-2 reporting. The Working Group continued its discussion on reporting CUSIP and CINS identifiers.
- FIF TRACE Working Group. The TRACE Working Group reviewed and discussed a draft FIF comment letter to the SEC relating to the April 22 SEC Orders requesting additional comments in response to (i) the January 11, 2024 FINRA rule filing to reduce to one minute the TRACE reporting timeframe for securities that are currently subject to a 15-minute reporting timeframe, and (ii) the January 12, 2024 MSRB rule filing to reduce the reporting timeframe for municipal bonds from 15 minutes to one minute.
- FIF Rule 605 Working Group. The Rule 605 Working Group reviewed a draft FIF comment letter to the SEC relating to implementation of the changes to Rule 605 that the SEC adopted on March 6, including the following issues and topics: required amendments to the Rule 605 NMS Plan; reporting for notional value orders that have a fractional share component; and various required FAQ amendments.
- FIF ATS Working Group. The ATS Working Group discussed questions from an FIF member relating to Form ATS-R reporting.
- FIF CAIS Clearing Subgroup. FIF hosted a call for the CAIS Clearing Subgroup. The Working Group discussed CAIS reporting challenges for the scenario where an introducing firm settles a customer account through multiple clearing firms.
- 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 a revised draft FIF comment letter to the SEC on the proposed plan amendments submitted by the CAT Plan Participants to reduce CAT operating costs. During the second call, the Working Group discussed a presentation from FINRA CAT relating to linkage of representative to customer orders and linkage of order fulfillments to representative and principal orders. The Working Group also discussed CAT reporting for RFQ responses that are not immediately actionable.
Eduard Kotlyar