26 September, 2022
Working Group Update 9/26/2022
26 September, 2022
- FIF TRACE Working Group. The TRACE Working Group continued its review of 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.
- FIF Rule 606 Working Group. The Rule 606 Working Group continued its discussion of a proposed alternative for Rule 606(a) reporting for options. The Working Group discussed recent guidance from FINRA to a firm on reporting routes to options floor brokers and options algo providers. The Working Group discussed whether a firm that has some order flow that requires look-through and other order flow that does not require look-through can report all of its order flow using look-through.
- FIF Back Office Committee. The Back Office Committee reviewed applicable FICC, DTC, NSCC, SEC, MSRB, OCC, IRS and FINRA updates during the past month, including a recent rule proposal by the SEC to require centralized clearing for trades in Treasury securities. Please find the Agenda here.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed issues and questions from FIF members on CAT reporting for a customer order that becomes executable on a specified future date, CAT reporting for pre-IPO orders, and the maximum compliance error rate for CAT. The Working Group discussed CAT reporting of port and other default settings by a routing party, reporting of verbal quotes, and reporting for representative orders.
- FIF CAIS Reporting Working Group. The CAIS Working Group reviewed a draft submission to the Plan Participants on duplicative errors. The Working Group discussed issues and questions from FIF members on LEI renewals, reporting for accounts that have been suspended, handling of Error Code 22533 (multiple instances of a CAT Customer with differing data), and issues with the Inconsistencies view in the CAIS portal. The Working Group reviewed updates to FAQ Q51 relating to reporting of the roleStartDate. The Working Group reviewed updates to the Technical Specifications on the maximum file size for SFTP submissions. The Working Group reviewed draft member comments and questions to FINRA CAT on reporting for closed accounts.
Eduard Kotlyar