06 March, 2023
Working Group Update 3/6/2023
06 March, 2023
- FIF Rule 605 Working Group. The Rule 605 Working Group continued its discussion of the SEC’s recent rule proposal on Disclosure of Order Execution Information, with a focus on how each item in the summary report should be calculated, weighted-average E/Q and the implementation time period.
- FIF SEC Equity Market Proposals Working Group (Order Competition Rule). The Working Group continued its discussion of the SEC’s recent rule proposal on Disclosure of Order Execution Information, including potential conflicts with FINRA Rule 5310.01 (execution of marketable customer orders), FINRA Rule 5320(a) (prohibition against trading ahead of customer orders) and FINRA Rule 5320.07 (crossing requirement). The Working Group also discussed orders for inter-listed securities, orders from a foreign broker-dealer, dividend reinvestment plan and automated investment plan purchases, priority of customer orders over broker-dealer orders, and the conditions that would need to apply before the first qualified auctions could be introduced into production.
- FIF SEC Equity Market Proposals Working Group (Reg NMS). The Working Group continued its discussion of the SEC’s recent rule proposal on Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders, including the scenario where the stock price crosses the $1 threshold, the process for notification of MPI changes, MPI changes for corporate events, stock splits and reverse stock splits, the impact of MPI changes on GTC orders, providing an exception to allow a non-executing firm to accept orders in any increment, and the potential impact on CAT costs and CAT system processing timelines.
- Front Office Committee. The Front Office Committee reviewed applicable updates and notices from the SEC, FINRA, FINRA CAT and the equity and option exchanges. Please find the agenda here.
- FIF CAT CAIS Working Group. The Working Group discussed the recent notification from FINRA CAT relating to the June and July 2023 CAIS deadlines that will be delayed and the ones that will remain.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed issues and questions from FIF members relating to the CAT erroneous self-report form and reporting for an order that has an expiration date and time. The Working Group discussed recent FINRA examinations relating to CAT reporting. The Working Group reviewed draft FIF member comments and questions for FINRA CAT relating to pre-IPO orders. The Working Group reviewed the most recent update to FAQ D10, relating to CASH orders. The Working Group discussed recent updates to the CAT release schedule. The Working Group discussed CAT reporting for RFQ responses.
Eduard Kotlyar