20 February, 2024
Working Group Update 2/20/2024
20 February, 2024
- Fractional Shares. The Working Group discussed a request for feedback from FINRA representatives relating to FINRA’s consideration of changes to the TRF and ORF reporting systems to allow for reporting of fractional shares.
- SEC Rule on Short Position and Short Activity Reporting. The FIF Short Sales / Reg SHO / Short Interest Reporting Working Group discussed issues and questions from FIF members relating to implementation of the SEC Rule on Short Position and Short Activity Reporting.
- FIF Rule 605 Working Group. FIF hosted a call for the Rule 605 Working Group to review and make final edits to a supplemental FIF comment letter on the SEC’s rule proposal to modernize Rule 605. FIF submitted this comment letter to the SEC.
- FIF TRACE Working Group. FIF hosted a call for the TRACE Working Group to review and make final edits to an FIF comment letter on (i) the January 11 rule filing by FINRA to reduce to one minute the TRACE reporting timeframe for securities that are currently subject to a fifteen-minute reporting timeframe and (ii) the parallel rule filing by the MSRB on January 12. FIF submitted this comment letter to the SEC.
- 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 discussed issues and questions from FIF members on CAT billing for CMTA scenarios, transactions subject to CAT fees but not subject to CAT billing, and billing for off-exchange transactions. The Working Group discussed mapping from TRF reports to CAT billing. The Working Group reviewed a draft FIF comment letter on CAT billing and reconciliation. During the second Working Group call, the Working Group discussed the filing by the CAT Plan Participants of an exemption request relating to RFQ responses. The Working Group discussed timestamps on routes to a winning RFQ bidder. The Working Group discussed draft comments and questions for FINRA CAT relating to the ND handlingInstructions value and the new auction-related handlingInstructions values. FIF submitted these comments and questions to FINRA CAT. The Working Group reviewed and discussed a draft FIF letter to the CAT Plan Participants and FINRA CAT requesting confirmation that firms can report to CAT order modifications that do not change the material terms of an order.
Eduard Kotlyar