25 March, 2024
Working Group Update 3/25/2024
25 March, 2024
- FIF Rule 606 Working Group / FINRA Rule 6151. FINRA hosted a call for FIF members on the recently-adopted FINRA Rule 6151, which requires industry members to submit their Rule 606(a) reports to FINRA. During the call, representatives from FINRA’s Office of General Counsel and FINRA’s Market Regulation and Technology groups provided an update on the implementation of FINRA Rule 6151. FINRA personnel also answered questions from FIF members.
- FIF Rule 605 Working Group. The Rule 605 Working Group discussed reporting under the current Rule 605for DNR (do not reduce) orders. The Working Group discussed reporting for fractional share orders and orders for omnibus accounts under the updated Rule 605.
- FIF 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 agenda here.
- FIF CAT CAIS Working Group. The CAIS Working Group discussed the FDID reconciliation report, the requirement to report information that no longer represents the current state of a CAT record, and data provided by the FINRA CAT helpdesk to an FIF member on the date that an FDID was reported to the CAT Transaction Reporting system. The Working Group continued its review of updates to the CAIS Reporting Scenarios document.
- 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 exemptive request letter relating to representative order linkage. The Working Group also reviewed a revised draft exemptive request letter relating to the reporting of port settings by a routing firm. FIF finalized and submitted these two exemptive request letters to the SEC. The Working Group also discussed the need for the ‘YE’ flag for order fulfillments for options. During the second call, the Working Group discussed various CAT billing and reconciliation issues and reporting the accountHolderType value.
Eduard Kotlyar