11 December, 2023
Working Group Update 12/11/2023
11 December, 2023
- Guidance from the SEC and FINRA on Fully-Paid Lending from a Foreign Omnibus Account. The Working Group discussed guidance received by an FIF member from the SEC and FINRA on conducting fully-paid lending from a foreign omnibus account.
- FIF CAT Monthly Update Working Group Call. The CAT Monthly Update Working Group reviewed guidance and updates from the CAT Plan Participants and FINRA CAT on CAT billing, CAT Transaction Reporting and CAT CAIS reporting during the prior month. The Working Group reviewed the current areas of focus for FIF members and the current open issues for CAT billing, CAT Transaction Reporting and CAT CAIS reporting.
- FIF CAIS Working Group. The CAIS Working Group continued its review of the November 29 FINRA CAT webinar presentation on 2024 CAIS releases. The Working Group reviewed the file schemas for rejections and material inconsistencies posted by FINRA CAT on November 30. The Working Group reviewed draft FIF member comments for FINRA CAT on the outstanding rejections file. FIF submitted these comments to FINRA CAT. The Working Group reviewed a draft FIF submission to FINRA CAT requesting clarification on the scope of events that represent a Mass Transfer. The Working Group discussed the status of the SRO exemption request relating to the CAT requirement for unique CCIDs.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed CAT reporting for inter-listed securities and ADRs, including how firms systematically identify inter-listed securities. The Working Group discussed reporting executions to CAT as manual vs. electronic. The Working Group discussed the timeline for implementation of CAT billing. The Working Group reviewed and discussed a revised draft FIF letter to the CAT Plan Participants and FINRA CAT on CAT billing. FIF submitted this letter to the CAT Plan Participants and FINRA CAT.
Eduard Kotlyar