18 March, 2024
Working Group Update 3/18/2024
18 March, 2024
- SEC Rule on Short Position and Short Activity Reporting. FIF hosted a call for the FIF Short Sales / Reg SHO / Short Interest Reporting Working Group to continue the discussion of issues and questions from FIF members relating to implementation of the SEC Rule on Short Position and Short Activity Reporting. The Working Group discussed the scope of reportable securities, identifying data sources for reportable securities, reporting for ADRs, reporting for dually-listed symbols, reporting by parent companies of positions held by subsidiaries, and applicability of the reporting requirements to non-US customers and positions in non-US securities.
- FIF Rule 605 and 606 Working Groups. FIF hosted a joint call for the Rule 605 and 606 Working Groups. During this call, the Working Group discussed FINRA Rule 6151, which requires firms to submit their Rule 606(a) reports to FINRA. The Working Group also discussed FINRA Rule 6470, which requires firms to prepare and submit to FINRA reports of routing activity for OTC equity securities. The Working Group reviewed FINRA Regulatory Notice 24-05, which discusses the implementation of Rules 6151 and 6470. The Working Group commenced a review of the amendments to Rule 605 recently adopted by the SEC. FIF also hosted a second call for the Rule 606 Working Group. During this call, the Working Group reviewed and discussed a draft FIF letter to FINRA relating to the implementation of FINRA Rule 6151. FIF submitted this letter to FINRA.
- FIF CAT CAIS Working Group. Working Group members provided additional feedback on the February 26 CAIS production release. The Working Group reviewed a response from FINRA CAT on the FIF member request to simplify the process for a reporting firm to delete a CAIS FDID record that was submitted in error. The Working Group discussed the requirement to report information that no longer represents the state of the record. The Working Group discussed the due date for resolving FDID validation errors. The Working Group reviewed draft FIF member comments and questions for FINRA CAT relating to CAIS peer groups, report cards and peer groups for clearing firms, the CAIS Compliance Glossary, feedback for rejections and Material Inconsistencies, the error for firmDesignatedID or newOrderFDID not found, the one-time feedback file of FDIDs not accepted in CAIS, and the ability to request additional account details from FINRA based on submitting an FDID. The Working Group commenced its review of the recent updates to the CAIS Reporting Scenarios.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed questions from FIF members about MEOF events, TRF reporting and the NYSE Equity Trade Journal file. The Working Group discussed a recent call with FINRA CAT representatives relating to the new auction-related handling instructions, CAT billing and reconciliation, and RFQ responses. The Working Group discussed a recent call with SEC representatives relating to the reporting of port settings, representative order linkages, RFQ responses that are not immediately actionable, and CAT billing and reconciliation. The Working Group reviewed and discussed a draft exemption request letter relating to linkage of representative to customer orders and linkage of order fulfillments to representative and principal orders.
Eduard Kotlyar