29 April, 2024
Working Group Update 4/29/2024
29 April, 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.
- Rule 605 Working Group. The Rule 605 Working Group continued its review and discussion on the changes to Rule 605 that the SEC adopted on March 6, including the following issues and topics: time for determining the marketability of orders received pre-open; the potential requirement for separate MPIDs; time of receipt for midpoint-or-better limit orders; share weighting for calculating the average midpoint; reporting for scenarios where the spread is wide; reporting for limit up – limit down scenarios; reporting for stop orders; and formatting for the detailed report.
- Rule 606 Working Group; FINRA Rule 6151 Implementation. The Rule 606 Working Group continued its discussion of issues relating to the implementation of FINRA Rule 6151 (centralized reporting of Rule 606(a) reports to FINRA). The Working Group reviewed the Filing Guide published by FINRA relating to Rule 6151 implementation. The Working Group discussed issues and questions from FIF members relating to Rule 606.
- Data and Technology Committee and Emerging Technologies Working Group. 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 Bill Bierds of the BCC Group, who discussed The Future of Market Data in the Cloud. FIF also invited the members of the Emerging Technologies Working Group to participate on this call. Please find the meeting materials here.
- 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 agenda here.
- CAIS Working Group. The CAIS Working Group discussed feedback from FINRA CAT on prior FIF member comments and questions on CAIS peer groups, report cards and peers groups for clearing firms, the CAIS Compliance Glossary, feedback for rejections and material inconsistencies, the error messages for firmDesignatedID or newOrderFDID not found, the one-time feedback file of FDIDs not accepted in CAIS, and the ability to request details from CAT based on an FDID. The Working Group discussed suggested enhancements to the CAIS portal from an FIF member. The Working Group reviewed draft FIF member comments and questions for FINRA CAT on ascending and descending functionality in the CAIS portal and the Type 2 Customer and Account Reporting Disclosure Form. The Working Group discussed a material inconsistencies scenario raised by an FIF member where two or more clearing firms report for the same introducing firm. The Working Group completed its review of the most recent updates to the CAIS Reporting Scenarios.
- CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group reviewed and made final edits to a revised draft FIF letter to the SEC relating to RFQ responses that are not immediately actionable. FIF submitted this letter to the SEC. The Working Group discussed CAT reporting for a scenario where two dealers trade with each other from inventory. The Working Group discussed follow-up by FINRA on late CAT filings. The Working Group discussed the recent updates to the Reporting Scenarios relating to NIA RFQ responses. The Working Group discussed the proposed Cost Savings Amendment filed by the CAT Plan Participants with the SEC on March 27 and the SEC’s Notice of Filing.
Eduard Kotlyar