14 August, 2023
Working Group Update 8/14/2023
14 August, 2023
- Customer Account Statements. FIF members continued their discussion on implementing recent amendments to FINRA Rule 2231 (Customer Account Statements), including scenarios where an agent under a power of attorney provides an address change for the account holder, how firms should respond to a potential challenge from an agent under a power of attorney who challenges a firm’s refusal to stop delivery to an incapacitated account holder, and whether firms intend to apply to FINRA for exemption requests.
- Retiring TRF Reporting Requirements that are Duplicative of CAT. FIF hosted a call for FIF members to discuss a draft letter to FINRA requesting the retirement of TRF reporting requirements that are duplicative of CAT (for example, regulatory reports to the TRF).
- Next Bridge Hydrocarbons Form S-1 Filing. FIF hosted a call for FIF members to discuss the recent Form S-1 registration statement filed by Next Bridge Hydrocarbons with the SEC to distribute non-transferable subscription rights only to holders who register their Next Bridge common stock directly with the company's transfer agent.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group continued its review and discussion of the July 31 updates to the CAT Phase 2d Technical Specifications relating to reporting for NIA (not immediately actionable) RFQ responses. The Working Group discussed a scenario where a responder sends a pegged price and the RFQ system displays updated prices to the solicitor as the reference price changes.
- FIF CAIS Working Group. The CAIS Working Group discussed recommending to FINRA CAT a change to CAIS that would enable a firm to use the DELETE function for any CAIS record with an error, regardless of the Error Code. This could be used by firms to remove an account that never had CAT reportable activity. The Working Group discussed how FINRA CAT uploading additional data to the CAIS portal would impact firm errors and Material Inconsistencies. The Working Group discussed CAT Alert 2023-01, “Interim Reporting Obligation 4 and Full CAIS Go-Live”. The Working Group discussed the recent CAIS FAQ updates. The Working Group discussed the recent updates to the CAIS known issues list. The Working Group reviewed the updated CAIS release schedule. The Working Group discussed the guidance recently added to the CAIS Technical Specifications that foreign Natural Person identifiers should not include dashes, spaces and similar characters that are not alpha-numeric.
Eduard Kotlyar