20 March, 2023
Working Group Update 3/20/2023
20 March, 2023
- FIF TRACE/Fixed Income Working Group. The TRACE Working Group discussed recent TRACE FAQ updates by FINRA relating to reporting the portfolio trade modifier and TRACE reporting for foreign sovereign bonds. The Working Group discussed questions from FIF members relating to TRACE reporting for Reg S transactions and currency conversion for TRACE reporting.
- 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 reporting the number of shares that could have been filled, reporting average percentage price improvement and average percentage spread, reporting average percentage realized spread, and the proposed summary report.
- FIF SEC Equity Market Proposals Working Group (Order Competition Rule). The Working Group discussed a revised draft of a comment letter on the SEC’s Order Competition Rule proposal, including applicability to held orders, executions against displayed orders on a continuous order book, the process for approving new qualified auction facilities and changes to these facilities, unsuccessful auctions, intermarket sweep orders, error corrections, fractional share orders, simultaneous auctions, capacity issues, and child routes.
- FIF SEC Equity Market Proposals Working Group (Reg NMS). The Working Group discussed the draft FIF comment letter on the SEC rule proposal on Regulation NMS: Minimum Pricing Increments, Access Fees and Transparency of Better Priced Orders, including MPI changes when a stock crosses the $1 threshold or is subject to a corporate event, the potential increase in message traffic resulting from the proposed MPI changes, implementation cost and timing, market resiliency issues, and the recommendation for a phased implementation of the proposed MPI changes.
- FIF Rule 606 Working Group. The Rule 606 Working Group discussed 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 CAT CAIS Working Group. The CAT CAIS Working Group discussed reporting for an account in a jurisdiction that issues a shared tax ID. The Working Group discussed CAIS reporting for various mass transfer scenarios and proposed changes to the process for reporting mass transfers to CAIS.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed clock synch procedures and reporting for firms that monitor on a periodic and a continuous basis. The Working Group discussed CAT reporting for a symbol that is subject to a corporate event. The Working Group discussed CAT reporting for RFQ responses.
Eduard Kotlyar