13 November, 2023
Working Group Update 11/13/2023
13 November, 2023
- FIF Securities Lending Transparency Working Group. Ignacio Sandoval of the Morgan Lewis law firm completed a review of the SEC’s recently-adopted rule to require Reporting of Securities Loans. The Working Group discussed various implementation issues relating to the rule proposal, including how end-of-day should be defined, timestamp granularity, how spread-based pricing should be reported to FINRA and disseminated by FINRA, reporting on an “if-known” basis, fees to be charged by FINRA to cover the costs of developing and operating the reporting system, and reporting for rolling/evergreen loans.
- FIF Rule 606 Working Group. The Rule 606 Working Group continued its discussion of Rule 606 reporting for the pass-through of CAT fees. The Working Group discussed issues and questions from FIF members relating to Rule 606 reporting.
- Regulatory Reporting Fines for 2022 and 2023. FIF hosted a call for the FIF Compliance and Surveillance Working Group and the FIF Regulatory Reporting Fines Working Group to continue the review of regulatory reporting fines for 2022 and 2023 for the following reporting activity: CAT, EBS, LOPR, Rule 605, Rule 606, short interest reporting, swap data reporting, TRACE, trade advertising and TRF/ORF. Prior to the call, FIF distributed to the participants of these Working Groups a digest of the reporting fines, with names and dates excluded.
- FIF CAIS Working Group. The CAIS Working Group discussed reporting of the AUTH3RD and AUTHREP roles. The Working Group discussed the November 1 updates to the CAIS open issues list on the CAT NMS Plan website. The Working Group discussed new FAQ Q72 relating to Mass Transfer of FDIDs.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed the Trade Detail Schemas for CAT billing published by FINRA CAT on November 6 and 7. The Working Group discussed various issues relating to CAT billing, including file size, inputting contacts, file specifications, re-routes by exchanges, cross trades, cancels and reversals, and fee rates. The Working Group reviewed a revised draft letter to the SEC on CAT reporting for not immediately actionable (NIA) RFQ responses. The Working Group commenced discussion of the SEC’s November 2 exemptive order for CAT, including reporting by a routing firm of settings applied by a receiving firm.
Eduard Kotlyar