06 May, 2024
Working Group Update 5/6/2024
06 May, 2024
- 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 continued its review of a draft FIF letter to the SEC requesting guidance on the implementation of Rule 13f-2.
- FINRA Trade Reporting Notice on Fractional Share Transactions. The FIF Data and Technology Committee and TRF/ORF Working Group discussed next steps in response to the March 22 FINRA Trade Reporting Notice on Upcoming Trade Reporting Enhancements for Fractional Share Transactions. The Committee and Working Group agreed that FIF would prepare a draft letter to FINRA to be reviewed by the Committee and Working Group during the next call. The Committee and Working Group agreed on the points to be included in the letter.
- FIF TRACE Working Group. The TRACE Working Group reviewed and discussed the April 22 SEC Order requesting additional comments in response to 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. The Working Group reviewed and discussed the SEC Order requesting additional comments in response to the January 12, 2024 MSRB rule filing to reduce the reporting timeframe for municipal bonds from 15 minutes to one minute. The Working Group agreed that FIF would draft a supplemental comment letter to the SEC for review by the Working Group during the next Working Group call.
- FIF Rule 605 Working Group. The Rule 605 Working Group continued its review and discussion of the changes to Rule 605 that the SEC adopted on March 6, including the following issues and topics: reporting for notional value orders that have a fractional share component; size improvement; determining the number of shares that could have filled an order while the order was in place; the implementation date for reporting; reporting for stop orders that are routed to another firm; reporting for pegged orders; determining which quote to use when there are multiple quotes within a time increment; and reporting the average midpoint.
- FIF Rule 606 Working Group; FINRA Rule 6151 Implementation. The Rule 606 Working Group reviewed a draft FIF letter to FINRA relating to the implementation of Rule 6151. FIF submitted this letter to FINRA. The Working Group discussed issues and questions from FIF members relating to Rule 606.
- 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 discussed potential regulatory enforcement for Material Inconsistencies. The Working Group discussed the Authorized Trader Names List. The Working Group reviewed the most recent updates to the CAIS Technical Specifications.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group reviewed and discussed a draft FIF comment letter on the proposed Cost Savings Amendment filed by the CAT Plan Participants with the SEC on March 27. The Working Group discussed the applicability of CAT reporting to OTC derivatives dealers. The Working Group reviewed a draft FIF FAQ on Order Modifications that only change the routedOrderID. FIF submitted this FAQ to the CAT Plan Participants and FINRA CAT. FIF updated the Working Group on recent discussions with FINRA CAT representatives on the machine-readable format for CAT invoices and the reporting of partial and full cancels and order modifications in the CAT Billing Trade Details file. The Working Group discussed an FIF member’s suggestions relating to file generation, error management and the CAT Transaction Reporting portal.
Eduard Kotlyar