11 March, 2024
Working Group Update 3/11/2024
11 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 based on settlement date versus trade date, determining the closing price when a trade is not executed on a settlement date, currency conversion for positions held in non-US currencies, and applicability of the reporting requirements to non-US customers and positions in non-US securities.
- FIF T+1 / Trade Date Affirmations Subgroup. The T+1 / Trade Date Affirmations subgroup continued the discussion of issues and questions from FIF members relating to the implementation of T+1 and the requirement for trade-date affirmations.
- FIF CAT Monthly Update Working Group Call. 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 CAT CAIS Working Group. The CAIS Working Group discussed CAIS peer groups, required updates to the CAIS Compliance Glossary, proposed enhancements to the feedback for rejections and Material Inconsistencies, a proposed request for the CAT system to notify a reporting firm whether an FDID was not submitted or was submitted and rejected, a proposed request for FINRA CAT to provide an updated list of FDIDs prior to the full CAIS compliance date, a proposed request for FINRA CAT to provide additional detail to a reporting firm relating to a rejection based on a firm submitting the FDID for the rejection, a proposed request to extend the current deadline for CAIS corrections, and potential CAIS-related topics to discuss during an upcoming call with FINRA CAT representatives.
- FIF CAT Transaction Reporting Working Group. FIF hosted two calls this past week for the CAT Transaction Reporting Working Group. The first call focused on CAT billing and reconciliation. During this call, the Working Group reviewed and provided final comments on the draft FIF comment letter on CAT billing and reconciliation. FIF submitted this comment letter to the SEC on March 4. During the second call, the Working Group discussed the current compliance date for representative order linkages. The Working Group reviewed and discussed the draft request for exemptive relief relating to representative order linkages submitted by FIF to the SEC during January 2023 and updates to this draft.
Eduard Kotlyar