13 March, 2023
Working Group Update 3/13/2023
13 March, 2023
- FIF Rule 605 Working Group. The Rule 605 Working Group discussed the first draft of a comment letter on the SEC’s rule proposal on Disclosure of Order Execution Information, including on the following topics: reporting time to execution for marketable orders that exceed the size of the protected quotation; reporting the number of shares that could have been filled; reporting average percentage price improvement and average percentage spread; and the proposed summary report.
- FIF SEC Equity Market Proposals Working Group (Order Competition Rule). The Working Group discussed the first draft of a comment letter on the SEC’s Order Competition Rule proposal, including the introductory section, potential conflicts with FINRA order handling rules, application of the auction requirement to market and marketable limit orders, and the approval and implementation process for a new qualified auction facility or a change to an existing qualified auction facility.
- OFR Proposal on Reporting for Bilateral Repos. The OFR Repo Reporting Working Group and the TRACE/Fixed Income Working Group participated on a call to discuss, and provide final comments on, the FIF comment letter on a recent proposal by the Treasury Department’s Office of Financial Research to require daily reporting for non-centrally cleared bilateral repos
- FIF CAT Monthly Update Working Group Call. The CAT Monthly Update Working Group 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 CAIS Working Group discussed the change in the CAIS Industry Testing Checkpoint calls from weekly to monthly. The Working Group discussed CAIS reporting for equity plan administration for corporate clients. The Working Group discussed CAIS reporting for various acquisition and disposition scenarios.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group provided an update on the withdrawal by the CAT Plan Participants of the Executed Share Model. The Working Group discussed updated FAQ B74 on CAT reporting when a security is delisted and new FAQ B77 on CAT reporting for a security that is subject to a corporate action. The Working Group discussed the planned changes to the CAT Transaction Reporting report card. The Working Group provided an update on a recent rule filing submitted by FINRA to update certain FINRA rules to remove requirements that are duplicative with CAT. The Working Group discussed a question from FINRA CAT about 3700 series linkage errors being included in the same linkage error file with other linkage errors.
Eduard Kotlyar