18 December, 2023
Working Group Update 12/18/2023
18 December, 2023
- FIF SEC Cyber, Reg SCI and Reg S-P Working Group. FIF hosted a call to review the SEC’s recent approval of a rule change by The Options Clearing Corporation (“OCC”) to enhance the cybersecurity obligations of OCC clearing members.
- Compliance with FINRA Clock Synch Requirements for Trading Systems in the Cloud; Validation of Compliance with Trading Halt Requirements. At the request of FIF members, FIF hosted a call to discuss compliance with FINRA clock synch requirements for trading systems in the cloud (including for CAT) and validation of compliance with trading halt requirements.
- Digital Assets Working Group. FIF hosted a call for the Digital Assets Working Group to discuss current implementation challenges for digital assets trading based on current regulations and potential approaches for addressing these challenges.
- FIF CAIS Working Group. The CAIS Working Group reviewed and discussed the December 6 FINRA CAT webinar on the new process for Material Inconsistencies.
- 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 and provided comments on a draft FIF letter to the SEC on the requirement for routing firms to report to CAT settings applied by receiving firms. During the second call, the Working Group reviewed a draft request for FINRA CAT to make available specific information to assist firms in obtaining approval of CAT LLC as a vendor to receive payment. FIF submitted this request to FINRA CAT. The Working Group reviewed a draft FIF letter to FINRA on CAT billing. FIF submitted this letter to FINRA. The Working Group reviewed the following recent documentation relating to CAT billing: CAT Technical Specifications for Billing Trade Details; CAT Billing Scenarios document; Trade Details Schema; and updates to the Industry Member Onboarding Guide. The Working Group reviewed comments from an FIF member to FINRA CAT on the CAT billing scenarios document.
Eduard Kotlyar