08 April, 2024
Working Group Update 4/8/2024
08 April, 2024
- SEC Rule on Short Position and Short Activity Reporting. The FIF Short Sales / Reg SHO / Short Interest Reporting Working Group continued its review and discussion of implementation issues relating to SEC Rule 13f-2 on Short Position and Short Activity Reporting, including identification of reportable securities, applicability of the Form 13F reporting requirements to Form SHO, reporting by affiliated groups, and application of the Form SHO reporting requirements to activity outside the US.
- FINRA Trade Reporting Notice on Fractional Share Transactions; SIAC and UTP notices on Fractional Share Reporting Enhancements. FIF hosted a call for the Data and Technology Committee and the TRF/ORF Working Group to discuss the Trade Reporting Notice published by FINRA on March 22, which announces an upcoming change to the TRF and ORF systems to support reporting of fractional share quantities. The effective date will be no earlier than the first calendar quarter of 2025. During the call, the group also discussed the Notices on SIP Fractional Share Reporting Enhancements published by SIAC and the UTP on March 28 and the associated changes to their technical specifications.
- FIF Rule 605 Working Group. The Rule 605 Working Group continued its review and discussion of the SEC’s recent amendments to Rule 605.
- FIF CAT Monthly Update Working Group. The CAT Monthly Update 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 CAT CAIS Working Group. The CAIS Working Group discussed CAIS reporting for trusts, including for unregistered trusts in foreign jurisdictions. The Working Group discussed draft FIF member comments and questions for FINRA CAT on the February 29 updates to the CAIS Reporting Scenarios and reporting information that no longer represents the current state of the record.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group reviewed the recent updates to the release schedule published by FINRA CAT, including updates relating to the ND handlingInstructions value, NIA RFQ responses, and the new SPHR value to support the MIAX Sapphire exchange. The Working Group discussed the FINRA Trade Reporting Notice on fractional share transactions and the potential impact on CAT billing. The Working Group discussed a draft FIF letter on Order Modifications that only change the routedOrderID. The Working Group discussed new FAQ R7 relating to the time period covered by the annual CAT Clock Synchronization Certification Form. The Working Group reviewed and discussed a draft FIF letter to the SEC on CAT reporting for RFQ responses that are not immediately actionable.
Eduard Kotlyar