09 January, 2023
Working Group Update 1/9/2023
09 January, 2023
- FIF Rule 606 Working Group. The Rule 606 Working Group discussed next steps relating to FINRA’s rule filing with the SEC on OTC routing disclosures. The Working Group discussed reporting of OTC Link routing scenarios under the FINRA rule filing. FIF is currently working on a draft supplemental comment letter on proposed reporting for trading activity involving the OTC Link ATS.
- FIF TRACE/Fixed Income Working Group. At the request of MSRB staff, on December 20, 2022 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”). The Working Group discussed the feedback and questions from the MSRB and obtained input from the Working Group on the items to be discussed with the MSRB during a planned follow-up call on January 10.
- 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 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 Working Group discussed the announcement by FINRA CAT that it will be disabling all Material Inconsistencies starting in January and the subsequent announcement by FINRA CAT that this will be implemented in testing on January 16 and in production on January 23. The Working Group discussed the change to the Technical Specifications providing for validation of FDIDs reported to the CAT Transaction Reporting system against FDIDs reported to CAIS and the subsequent announcement by FINRA CAT that this will not be introduced during January. The Working Group reviewed and discussed recommendations on implementation of Full CAIS to be submitted by FIF to FINRA CAT and the Plan Participants.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed FINRA inquiries on firms reporting pending FDIDs to CAT. The Working Group reviewed the December 16, 2022 updates to the Phase 2d Technical Specifications document. FIF updated the Working Group on the letter submitted by FIF to the SEC on December 16 relating to CAT reporting for verbal activity. The Working Group reviewed a draft exemptive request letter from FIF to the SEC on linkage of representative to customer orders and linkage of order fulfillments to representative and principal orders. The Working Group discussed the draft FIF exemptive request letter on CAT reporting of port settings by order routers.
Eduard Kotlyar