17 April, 2023
Working Group Update 4/17/2023
17 April, 2023
- FIF SEC Cyber, Reg SCI and Reg S-P Proposals Working Group. The Working Group reviewed and discussed the SEC’s recent cybersecurity rule proposal.
- FIF Cybersecurity Working Group. Greg Markovich, Senior Director in the FINRA Cyber Enabled Fraud (CEF) Group, presented to the FIF Cybersecurity Working Group, the FIF Compliance and Surveillance Working Group, and the newly-formed FIF SEC Cyber, Reg SCI and Reg S-P Working Group on FINRA’s 2023 cyber-related priorities and the results of prior FINRA cyber audits. FIF would like to thank Jim Dolan, the Chair of the FIF Cybersecurity Working Group, for arranging this presentation.
- FIF TRACE Working Group. The TRACE Working Group discussed TRACE reporting of the portfolio trade modifier, communicating to the MSRB the importance of enabling direct reporting if the MSRB intends to reduce the reporting timeframe for munis to one minute, and recent technical notices from FINRA relating to TRACE reporting for foreign sovereign bonds and other upcoming TRACE changes.
- FIF Rule 606 Working Group. The Rule 606 Working Group discussed and provided comments on a draft FIF response to the response by FINRA to the SEC’s March 3, 2023 “Order Instituting Proceedings to Determine Whether to Approve or Disapprove Proposed Rule Change to Adopt FINRA Rules 6151 (Disclosure of Order Routing Information for NMS Securities) and 6470 (Disclosure of Order Routing Information for OTC Equity Securities).” The Working Group discussed Rule 606 reporting for an aggregated order scenario presented by an FIF member.
- FIF CAT Monthly Update Working Group Call. The CAT Monthly Update Working 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 CAIS Working Group. The CAT CAIS Working Group reviewed and discussed a draft submission to FINRA CAT relating to full data replacement. The Working Group discussed updated guidance from the FINRA CAT helpdesk on CAIS reporting for corporate equity plan administration accounts. The Working Group continued its discussion of CAIS reporting for acquisitions. The Working Group discussed CAIS reporting for customer records that are added and removed while an FDID is in an error state.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed a request from the SEC for information relating to the level of verbal activity relative to all trading. The Working Group continued its discussion of CAT reporting for RFQ responses.
Eduard Kotlyar