03 October, 2022
Working Group Update 10/3/2022
03 October, 2022
- FIF TRACE Working Group. The TRACE Working Group discussed and provided final comments on a draft FIF comment letter on FINRA Regulatory Notice 22-17 and MSRB Notice 2022-07. These regulatory notices propose that trades in corporate, agency and municipal bonds be reported as soon as practical and no later than one minute after execution.
- Cybersecurity and Compliance Working Groups. FIF held a joint call for the Cybersecurity and Compliance Working Groups. The Working Groups discussed a request sent by the SEC to FIF to discuss a planned rule proposal by the SEC relating to cybersecurity. The following is a description of the rule proposal from the SEC’s most recent regulatory agenda: “The Division is considering recommending that the Commission propose rules to address registrant cybersecurity risk and related disclosures, amendments to Regulation S-P and Regulation SCI, and other enhancements related to the cybersecurity and resiliency of certain Commission registrants.” The Working Group discussed the SEC’s recent cybersecurity rule proposal for investment advisers and registered investment companies, the current Reg SCI requirements relating to cybersecurity, and the current NYDFS and FTC cyber regulations.
- 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 Mark Schaedel of DataBP, who provided an update on the current status of efforts to introduce a consolidated tape in Europe. Please find the meeting materials here and the larger capacity statistics deck here.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group reviewed draft comments for FINRA CAT on reporting for pre-IPO orders. FIF submitted these comments to FINRA CAT. The Working Group discussed allocating CAT costs for prior periods based on current vs. historical market share. The Working Group discussed a recent NYSE Regulatory Memo on disclosure of accounts by registered market makers and, more generally, the need to terminate regulations that are duplicative of CAT. The Working Group discussed a Manning scenario relating to linkage of order fulfillments to representative orders. FIF submitted this scenario to the SEC staff in advance of a scheduled call with the SEC. FIF participated on a call with CAT Advisory Committee members relating to reporting for verbal quotes.
- FIF CAIS Reporting Working Group. FIF submitted a letter to the CAT Plan Participants requesting expedited implementation of recent proposals by FINRA CAT to address the CAIS system generating duplicative errors and processing certain Material Inconsistencies as errors. The Working Group reviewed draft FIF member comments FINRA CAT on CAIS reporting for closed accounts. FIF submitted these comments to FINRA CAT. The Working Group discussed various errors that firms are experiencing in production. The Working Group discussed a recent presentation by FINRA CAT on reporting the correspondentCRD field.
Eduard Kotlyar