01 May, 2023
Working Group Update 5/1/2023
01 May, 2023
- Options Clearing Corporation Cybersecurity Rule Proposal. FIF hosted two calls for the Cybersecurity Working Group and the Compliance and Surveillance Working Group to review and edit a draft FIF comment letter to the SEC on a rule filing submitted by The Options Clearing Corporation to the SEC that would require immediate notification of security incidents to the OCC and various follow-up notification requirements. FIF submitted this comment letter to the SEC.
- FIF SEC Cyber, Reg SCI and Reg S-P Proposals Working Group. The Working Group continued its review and discussion of the SEC’s recent rule proposal for amendments to Regulation SCI and also discussed the SEC’s recent rule proposal for amendments to Regulation S-P.
- FIF TRACE/Fixed Income Working Group. The TRACE Working Group reviewed a draft supplemental comment letter to the MSRB. The Working Group discussed various scenarios relating to reporting of the TRACE portfolio trade modifier. The Working Group reviewed draft FIF member comments and questions for FINRA relating to the TRACE API Specifications document, the TRACE New Issue Form, and the timing for reporting Treasury hedge transactions in connection with an offering.
- Data & Technology Committee. The Data and Technology Committee reviewed capacity, latency and volume data for the prior month for the equity, options, currency, crypto and futures markets. Mike Collazo and Brian Faughnan from SIAC provided an update on the expansion of OPRA to 96 lines. John Ramsay of IEX provided an update on the recent rule filing by FINRA with the SEC to add an ADF participant. Please find the meeting materials here and the full capacity statistics here.
- Front Office Committee. The Front Office Committee reviewed applicable updates and notices from the SEC, FINRA, FINRA CAT and the equity and option exchanges. Please find the agenda here.
- FIF CAT CAIS Working Group. The CAIS Working Group discussed the recent announcement by FINRA CAT about the Full CAIS Compliance date. The Working Group discussed follow-up questions to submit to FINRA CAT relating to this announcement. The Working Group reviewed and discussed the CAIS validation changes proposed by FINRA CAT during a presentation in June 2022. The Working Group discussed proposed future changes to CAIS to reduce the number of CAIS rejections and allow additional data to be accepted in CAIS and available to regulatory and surveillance personnel.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group reviewed and discussed a recent request submitted by the CAT Plan Participants to the SEC to extend from July 31, 2024 to January 31, 2025 exemptive relief granted by the SEC on June 8, 2022. The Working Group reviewed and discussed a draft FIF note to FINRA on the CAT Self-Reporting Erroneous Events form. The Working Group discussed recent inquiries from FINRA CAT and FINRA on CAT reporting for representative orders. The Working Group discussed a proposal by the Plan Participants to provide for scheduled linkage in the CAT production mirror environment. The Working Group reviewed a recent update to CAT FAQ D10 relating to CAT reporting for CASH orders. The Working Group reviewed the April 11 updates to the CAT Phase 2d Technical Specifications document.
- FIF CAT Transaction Reporting Working Group: RFQ Responses. FIF hosted an additional call for the CAT Transaction Reporting Working Group this week focused on reporting for RFQ responses. The Working Group discussed the five RFQ reporting scenarios presented by FINRA CAT. The Working Group discussed reporting for RFQ responses that update multiple times per second. The Working Group discussed FINRA CAT’s proposed linkage requirements for RFQ response scenarios. The Working Group discussed each field within the CAT New Quote event and its applicability for RFQ responses.
Eduard Kotlyar