12 September, 2022
Working Group Update 9/12/2022
12 September, 2022
- FIF TRACE Reporting Working Group. The TRACE Reporting Working Group reviewed the recent SEC approval of SR-FINRA-2022-013, which requires trades in Treasuries to be reported “as soon as practicable, but no later than … 60 minutes of the Time of Execution” and also requires that electronically executed transactions in Treasuries be reported “to the finest increment of time captured by the execution system”. FIF provided an update on an FIF call with FINRA relating to FINRA’s consideration of a requirement for firms to report quotes in fixed income securities to FINRA. The Working Group reviewed draft FIF member questions for FINRA relating to TRACE reporting for Covered Depository Institutions and TRACE reporting of foreign sovereign bonds. The Working Group continued its review of a draft FIF comment letter on FINRA Regulatory Notice 22-17, “TRACE Reporting Timeframe: FINRA Requests Comment on a Proposal to Shorten the Trade Reporting Timeframe for Transactions in Certain TRACE-Eligible Securities From 15 Minutes to One Minute” (August 2, 2022) and MSRB Notice 2022-017, “Request for Comment on Transaction Reporting Obligations under MSRB Rule G-14” (August 2, 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 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 Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed whether firms whether firms include the mark-up and mark-down in the price field for CAT Allocation events. The Working Group reviewed feedback from FINRA CAT on previously-submitted FIF member comments and questions related to the following: reporting the limit price for a mark-up, mark-down scenario; reporting for notional value orders; reporting allocations to DVP accounts; reporting responses to RFQs; segmenting report cards by IMID; and the RLO (Retail Liquidity Order) and IDX (Intra-Day Crossing) handlingInstructions values. The Working Group reviewed the August 24 updates to the Phase 2d Technical Specifications. The Working Group provided an update on a call with FINRA CAT, FIF and FIF members relating to clock synch and electronic timestamp increments. The Working Group reviewed the SEC’s August 30 order instituting proceedings to determine whether to approve the most recent CAT fee filing by the CAT Plan Participants. The Working Group reviewed a scenario to be presented to the SEC relating to CAT reporting for fulfillment of representative orders.
- FIF CAT CAIS Reporting Working Group. The CAIS Reporting Working Group discussed recent updates to FAQs Q58 (reporting the UNPARSED value in the firstName field), T7 (reporting the role field where an industry member has authority to place orders for an account), and Q42 (reporting the fdidDate). The Working Group discussed new FAQs Q65 (Authorized Trader Names List), Q66 (reporting for a DVP/RVP account where the custodian is not identified), and Q67 (reporting addresses at the customer and account levels). The Working Group reviewed updates to CAT Alerts 2022-01 (Full CAIS Reporting Timeline and Interim Reporting Obligations) and 2021-04 (Transitioning from LTID Account Phase to Full CAIS Phase). The Working Group discussed issues and questions from FIF members relating to Error Code 30003 for EIN Material Inconsistences, slowness with the FDID reconciliation report on the CAIS reporter portal, retrieving a CAIS record through the portal, the length of the CAIS address fields, ending a ULTID when an LTID is received, and reporting trusts to CAIS.
Eduard Kotlyar