24 April, 2023
Working Group Update 4/24/2023
24 April, 2023
- Options Clearing Corporation Cybersecurity Rule Proposal. FIF hosted a call for the Cybersecurity Working Group and the Compliance and Surveillance Working Group to discuss 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 SEC Cyber, Reg SCI and Reg S-P Proposals Working Group. The Working Group continued its review and discussion of the SEC’s recent cybersecurity rule proposal and also discussed the SEC’s recent rule proposal for amendments to Regulation SCI.
- FIF Back Office Committee. The Back Office Committee reviewed applicable FICC, DTC, NSCC, SEC, MSRB, OCC and FINRA updates during the past month. Please find the monthly Agenda here.
- FIF TRACE/Fixed Income Working Group. FIF submitted comments and questions to FINRA relating to TRACE reporting of the portfolio trade modifier and other TRACE reporting matters.
- FIF CAT CAIS Working Group. The CAIS Working Group discussed various scenarios that involve cascading errors, including where an FDID and all associated customer records reject when one associated customer record is rejected. The Working Group discussed CAIS reporting for inherited assets. FIF submitted comments and questions to FINRA CAT on the CAIS full data replacement procedure and CAIS reporting for corporate equity plan administration accounts.
- FIF CAT Transaction Reporting Working Group. FIF hosted three calls this week on CAT Transaction Reporting. The first call focused on the mechanics of the CAT fee collection process. The second call focused on CAT reporting for RFQ responses. On the third call the Working Group: reviewed a recent filing by the Plan Participants with the SEC on CAT reporting of certain verbal activity; reviewed and edited a draft FIF response to a question from the SEC on CAT reporting of verbal quotes; discussed the CAT Self-Reporting Erroneous Events form; discussed CAT errors that are more than three months old; discussed the potential impact on CAT reporting of recently adopted and proposed SEC rules; and discussed recent FINRA audit findings relating to CAT reporting and clock synchronization.
Eduard Kotlyar