20 November, 2023
Working Group Update 11/20/2023
20 November, 2023
- Margin Requirements for Covered Agency Transactions. Ignacio Sandoval of the Morgan Lewis law firm reviewed the new margin requirements for Covered Agency Transactions, which are scheduled to take effect on May 22, 2024. FIF invited the members of the FIF Back Office Committee and the FIF Financial Risk Regulations Working Group to participate on this call.
- Back Office Committee; Spotlight on T+1. The Back Office Committee reviewed applicable FICC, DTC, NSCC, SEC, MSRB, OCC, IRS and FINRA updates during the past month. The spotlight presenter was George Bollenbacher of Capital Market Advisors, who discussed Getting to T+1 Settlement. Please find the agenda here.
- Electronic Recordkeeping. At the request of an FIF member, FIF hosted a call for the FIF electronic recordkeeping sub-group to discuss the requirement under SEC Rule 17a-11(c) for a broker-dealer to provide same-day notice to the SEC and FINRA if the firm fails to make and keep current any books and records required by SEC Rule 17a-3.
- FIF CAIS Working Group. The CAIS Working Group discussed new FAQ Q72 relating to CAIS reporting for a Mass Transfer of FDIDs. The Working Group discussed various issues relating to reporting of Mass Transfers to CAIS, including scenarios where further clarification is required. The Working Group discussed recent guidance from the FINRA CAT helpdesk to an FIF member on reporting the AUTHREP role.
- FIF CAT Transaction Reporting Working Group. FIF hosted two calls this week for the CAT Transaction Reporting Working Group. During the first Working Group call, the Working Group reviewed a draft FIF letter to the SEC relating to CAT reporting for RFQ responses that are not immediately actionable. The Working Group also reviewed a draft FIF letter to the SEC relating to CAT reporting by a routing firm of settings applied by a receiving firm. During the second Working Group call, the Working Group continued its discussion of issues relating to the implementation of CAT billing, including record limitations for the underlying trade details files, providing invoices to reporting and submitting firms, reporting of cross trades, and reporting of trade cancels and modifications. On Friday, FIF members participated on a call with SEC representatives relating to the implementation of CAT billing.
Eduard Kotlyar