27 March, 2023
Working Group Update 3/27/2023
27 March, 2023
- FIF SEC Equity Market Proposals Working Group (Reg NMS). The Working Group discussed a revised draft of the FIF comment letter on the SEC rule proposal on Regulation NMS: Minimum Pricing Increments, Access Fees and Transparency of Better Priced Orders, including the potential increase in message traffic resulting from the proposed MPI changes, implementation process and timing, market resiliency issues, and the recommendation for a phased implementation of the proposed MPI changes.
- FIF Rule 605 Working Group. The Rule 605 Working Group discussed a revised draft of the FIF comment letter on the SEC’s rule proposal on Disclosure of Order Execution Information, including separate reporting for round lots and odd lots, separate reporting for fractional shares, reporting average percentage spread, reporting based on the order receipt time, and reporting for not held orders.
- FIF SEC Equity Market Proposals Working Group (Order Competition Rule). The Working Group discussed a revised draft of the FIF comment letter on the SEC’s Order Competition Rule proposal, including potential exclusions for directed and not held orders, the ability to submit an auction response that can interact with multiple qualified auctions, the ability for an OCTC to cross segmented orders, pegged auction responses, and limit orders not executed in an open auction.
- Large Options Positions Reporting (LOPR). FIF hosted a call for FIF members to discuss LOPR reporting for an OTC options call spread that involves a sequence of daily maturing options. The group also discussed other LOPR reporting issues raised by FIF members during the call.
- FIF Rule 606 Working Group. FIF sent to the Rule 606 Working Group a draft response to the SEC order seeking further comment on the FINRA rule proposal on disclosure of order routing information for OTC equity securities and NMS securities. FIF plans to submit a response to the SEC this week.
- FIF Back Office Committee. The Back Office Committee reviewed applicable FICC, DTC, NSCC, SEC, MSRB, OCC, IRS and FINRA updates during the past month. Please find the March Agenda here.
- FIF CAT CAIS Working Group. The CAIS Working Group discussed CAIS reporting for corporate equity plan administration accounts. The Working Group discussed draft comments and questions for FINRA CAT relating to mass transfer scenarios where the clearing firm maintains the account, proposed changes to the automated transfer procedure for mass transfers, and CAIS reporting for jurisdictions that issue a shared identifier.
- FIF CAT Transaction Reporting Working Group. FINRA CAT representatives presented to the FIF CAT Transaction Reporting Working Group a proposed framework for reporting non-actionable RFQ responses to CAT.
Eduard Kotlyar