19 September, 2022
Working Group Update 9/19/2022
19 September, 2022
- FIF OTC Options Reporting Working Group. The OTC Options Reporting Working Group continued its review of a draft FIF comment letter on FINRA Regulatory Notice 22-14, “OTC Options Reporting: FINRA Requests Comment on Proposed Trade Reporting Requirements for Over-The-Counter Options Transactions”. FIF plans to submit this comment letter later today.
- FIF Tax Information Reporting Working Group. Representatives from the EY Tax Team presented on IRC 1446(f), withholding on dispositions of interests in publicly traded partnerships. The next meeting will take place on 10/20 @ 2pm ET.
- FIF TRACE Working Group. FIF submitted to FINRA FIF member questions and requests relating to TRACE reporting by Covered Depository Institutions and TRACE reporting for foreign sovereign bonds.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed reporting the accountHolderType value for orders from a foreign affiliate that is not a broker-dealer. The Working Group reviewed a draft representative order scenario to be presented to the SEC. The Working Group discussed the reporting of verbal quotes and the exemption requested submitted by the CAT Plan Participants. The Working Group reviewed a presentation by an FIF member on reporting the deskOrderID.
- FIF CAT CAIS Reporting Working Group. The CAT CAIS Working Group discussed inquiries received by FIF members from FINRA relating to Full CAIS reporting errors. The Working Group discussed the need for the retirement of Large Trader Reporting and the retirement of Electronic Blue Sheets for equities and options. The Working Group reviewed draft member comments and questions for FINRA CAT relating to firms receiving the same Material Inconsistency every day even after submitting a confirming update notification, the Plan Participant announcement to remove the addressList field at the FDID level as of July 12, 2023, FAQ Q4 on reporting the fdidDate, and the FDID Reconciliation Report. The Working Group discussed feedback from FINRA CAT during a call with FIF and the FIF Co-Chairs on September 13 relating to FAQ Q42 (fdidDate), FAQ Q51 (roleStartDate), the CAIS Monthly Report Card Glossary for Full CAIS, the computation of report card errors for Full CAIS, the BD customerType value, feedback for Material Inconsistencies, the FDID Reconciliation Report, proposed CAIS validation changes, the FDID Refresh Report and CAIS errors relating to closed accounts. The Working Group discussed responses from FINRA CAT during the September 14 CAIS Industry Testing Checkpoint call on FINRA inquiries relating to Full CAIS reporting errors, disregarded entities, the requirement to reconfirm the same Material Inconsistency on a daily basis, the processing time for large files, and reporting addresses at the FDID and CAT Customer levels.
Eduard Kotlyar