12 February, 2024
Working Group Update 2/12/2024
12 February, 2024
- FIF Rule 605 Working Group. FIF hosted two calls this past week for the Rule 605 Working Group. During both calls the Working Group reviewed and edited a draft FIF comment letter to the SEC on the SEC’s rule proposal to modernize Rule 605.
- FIF TRACE Working Group. The TRACE Working Group reviewed and discussed a revised draft of 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. The Working Group also discussed the upcoming platform changes for the FINRA system for reporting Treasuries to TRACE.
- Tax Information Reporting Working Group. Representatives from Wolters Kluwer discussed tax considerations for trading Bitcoin ETFs.
- FIF CAIS Working Group. The Working Group discussed the January 29 changes to the CAIS test environment. The Working Group discussed the recent updates to the CAIS schema file. The Working Group discussed a draft request to FINRA CAT to allow for the deletion of CAIS errors based on the FDID without restating all fields.
- FIF CAT Transaction Reporting Working Group. FIF hosted three calls this past week for the CAT Transaction Reporting Working Group. During the first call, the Working Group continued its discussion of CAT billing and reconciliation. During the second Working Group call, the Working Group discussed the reporting of the ND (Next Day) and SLR (Seller’s Option) handlingInstructions value when T+1 takes effect. The Working Group discussed the upcoming changes to the auction-related handlingInstructions values. The Working Group discussed reporting for algo orders with an end-of-day expiration time. The Working Group discussed the current status on reporting for not immediately actionable RFQ responses. The Working Group discussed firm compliance with the requirement for a periodic review of CAT against books and records. The Working Group discussed the reporting of the affiliateFlag field in the scenario where a firm has blanket authorization to trade on behalf of an affiliate. During the third call, the Working Group discussed the upcoming requirement for linkage of representative to customer orders and linkage of order fulfillments to principal and riskless principal orders.
Eduard Kotlyar