07 August, 2023
Working Group Update 8/7/2023
07 August, 2023
- Fractional Share or Fractional Bond Received from a Corporate Action. FIF members discussed processing and reporting for a scenario where a customer receives a fractional share or fractional bond as a result of a corporate action, and the fractional share or fractional bond allocation is subsequently liquidated as an account maintenance function.
- Reconciliation Process for Section 31 Fees. FIF members discussed enhancing the reconciliation process for Section 31 fees.
- Customer Account Statements. FIF members continued their discussion of the recent amendments to FINRA Rule 2231 (Customer Account Statements), including new Interpretation .07 (Logos, Trademarks, etc.), whether a general power of attorney is sufficient as customer consent for delivery of statements to a third-party, the potential for a firm to apply to FINRA for an exception from sending statements to a customer where the firm is concerned about the customer’s capacity, and whether a firm can permit a power of attorney to designate additional recipients.
- 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 Transaction Reporting and CAT CAIS reporting during the prior month. The Working Group also reviewed the current areas of focus for FIF members and the current open issues for CAT Transaction Reporting and CAT CAIS reporting.
- FIF CAT Transaction Reporting Working Group. FIF hosted two calls this week for the CAT Transaction Reporting Working Group. On the first call, FIF members reviewed and provided final comments on a joint FIF and SIFMA comment letter to the SEC on the magnitude of CAT costs. FIF submitted this comment letter to the SEC on July 31. On the second call, the CAT Working Group commenced its review of the updated Phase 2d Technical Specifications published by FINRA CAT on July 31 (Version 4.0.0 r20), including reporting for NIA (not immediately actionable) RFQ responses.
Eduard Kotlyar