30 January, 2023
Working Group Update 1/30/2023
30 January, 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, including order type categories, reporting based on notional value, reporting for orders received after the open and prior to the primary listing market disseminating its first firm quotations for the applicable security, reporting for mid-peg orders, reporting for segregated orders, providing an exemption for an introducing firm that routes all orders to its clearing firm, reporting for IOC and stop orders, removing the beyond-the-midpoint limit order category, and time granularity for reporting.
- FIF TRACE/Fixed Income Working Group. The TRACE/Fixed Income Working Group reviewed and provided final comments on the FIF comment letter on FINRA Regulatory Notice 22-26 (“FINRA Requests Comment on Proposed Changes to TRACE Reporting Relating to Delayed Treasury Spot Trades”). The Working Group continued its discussion of FINRA Regulatory Notice 22-28, “TRACE Reporting of Foreign Sovereign Debt Securities: FINRA Adopts Amendments to Require Reporting of Transactions in U.S. Dollar-Denominated Foreign Sovereign Debt Securities to TRACE”. The Working Group discussed TRACE reporting for Reg S transactions and transactions in non-US currencies.
- OFR Proposal on Reporting for Bilateral Repos. FIF hosted a call to discuss a recent proposal by the Treasury Department’s Office of Financial Research to require daily reporting for non-centrally cleared bilateral repos. FIF invited members of the new OFR Repo Reporting Working Group and the TRACE/Fixed Income Working Group to participate on this call.
- FIF Back Office Committee. The Back Office Committee reviewed applicable FICC, DTC, NSCC, SEC, MSRB, OCC, IRS and FINRA updates during the past month. The spotlight presenter was Sheila Zak of the Options Clearing Corporation, who provided an update on the OCC’s planned multi-year transition from ENCORE to the new Ovation platform (planned for launch in 2025).
- FIF Data and Technology Committee. The Data and Technology Committee reviewed capacity, latency and volume data for the prior month for the equity, options, currency, crypto and futures markets. The spotlight presenter was Tim Baker of Expero, who discussed the Financial Data Transparency Act (FDTA). The FDTA requires the SEC and other financial regulators to develop common standards that promote the organization, readability and availability of financial data they collect from regulated institutions.
- FIF CAT CAIS Working Group. FIF had a call with FINRA representatives on January 24 to discuss recent FINRA inquiries sent to firms relating to firm CAIS errors for FDIDs that have LTIDs. The Working Group discussed the feedback received from FINRA during that call. The Working Group also discussed guidance that firms have received directly from FINRA personnel relating to these inquiries. The Working Group discussed the recent removal of Material Inconsistencies from the CAIS test and production environments. The Working Group discussed challenges with the currently-scheduled compliance date for Full CAIS.
Eduard Kotlyar