07 November, 2022
Working Group Update 11/7/2022
07 November, 2022
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed a draft letter to the SEC on reporting of verbal quotes. The Working Group discussed a planned upcoming call with the CAT Operating Committee to discuss the submission of certification testing results to CAT. The Working Group discussed a survey request to be sent by FIF to FIF members on the use of the YE code for rep orders where the customer order is received electronically from another system. The Working Group discussed collecting cost estimates on reporting linkage of rep orders and order fulfillments for unlinked systems. The Working Group reviewed new FAQ U31 on reporting of the accountHolderType field by clearing firms. The Working Group reviewed the most recent updates to the Phase 2d Reporting Scenarios document.
- FIF CAT CAIS Working Group. The CAIS Working Group discussed the inaccurate reporting of errors through the portal. The Working Group discussed the one-off rejections file from FINRA CAT. The Working Group discussed new FAQs Q69 (reporting for multiple CAT Customers for an FDID with the same EIN) and Q70 (reporting for a piggyback clearing scenario). The Working Group discussed the recent filing by the CAT Operating Committee of an exemptive letter relating to the CAT NMS Plan requirement for a unique CCID for every CAT Customer. The Working Group discussed comments and questions from FIF members on: the scenario where an Authorized Trader is a government employee acting in the capacity of a guardian or conservator for a minor or incapacitated person; removing duplicate EIN fields in the CAIS portal; closed accounts where a firm is not able to resolve a prior CAIS error; reporting for multiple CAT Customers for an FDID with the same EIN; portal feedback; and reporting for DVP/RVP sub-accounts.
Eduard Kotlyar