17 January, 2023
Working Group Update 1/17/2023
17 January, 2023
- FIF Rule 605 Working Group. The Rule 605 Working Group discussed the SEC’s recent rule proposal on Disclosure of Order Execution Information.
- FIF TRACE/Fixed Income Working Group (MSRB RTRS reporting). On January 10, FIF and FIF members participated on a call with MSRB representatives to discuss the comment letter that FIF submitted in response to MSRB Notice 2022-07 (“Request for Comment on Transaction Reporting Obligations under MSRB Rule G-14”). During the call with MSRB representatives, FIF members discussed the importance of providing executing firms the ability to report directly to the RTRS reporting system. FIF members also discussed challenges with reporting specific types of trade executions within one minute, including manual trade executions, trade executions involving large programs, trade executions when a firm has not previously traded the bond that the firm must report, and trade executions that must be reported when the TRACE system opens.
- FIF TRACE/Fixed Income Working Group (TRACE reporting). The TRACE/Fixed Income Working Group reviewed and provided comments on the first draft of a comment letter on FINRA Regulatory Notice 22-26 (“FINRA Requests Comment on Proposed Changes to TRACE Reporting Relating to Delayed Treasury Spot Trades”).
- FIF CAT CAIS Working Group. The CAIS Working Group completed its review of draft recommendations to submit to the CAT Operating Committee and FINRA CAT relating to Full CAIS implementation. These recommendations included introducing Material Inconsistences as a separate phase of Full CAIS, providing firms a minimum eight-week testing period after all material known issues have been resolved, removing duplicative errors, providing firms the opportunity to reseed their CAIS data, removing all data from the test environment, and blocking firms from submitting tidValue entries that are not correct hashes of the associated EIN or LEI. FIF members also recommended that the CAT Operating Committee and FINRA CAT delay including the validation of CAT Transaction Reporting events against CAIS FDID data in firm report cards until the third monthly cycle after the Full CAIS live date. FIF submitted these recommendations to the CAT Operating Committee and FINRA CAT on January 11.
Eduard Kotlyar