22 August, 2022
Working Group Update 8/22/2022
22 August, 2022
- FIF OTC Options Reporting Working Group. The OTC Options Reporting Working Group continued its review of the 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”.
- Back Office Committee. The Back Office Committee reviewed applicable FICC, DTC, NSCC, SEC, MSRB, OCC, IRS and FINRA updates during the past month. The spotlight presenter was Renuka Gupta of OASIS Pro Markets, who discussed The Potential for Blockchain in Settlement. Please find the Agenda here.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group reviewed recent FAQ updates from FINRA CAT on reporting the accountHolderType field. The Working Group reviewed a request for feedback from the Plan Participants on the CAT fee collection process. The Working Group reviewed draft FIF comments to FINRA relating to the CAT rapid remediation process and FINRA trade surveillance requests. FIF submitted these comments to FINRA. The Working Group discussed reporting of port and other default settings by sending and receiving firms.
- FIF CAT CAIS Working Group. The CAIS Working Group reviewed and discussed the request for exemption submitted by the Plan Participants to the SEC relating to CAIS LTID Phase reporting. The Working Group discussed issues and questions from FIF members relating to a centralized source for EINs, the CAIS system generating duplicate errors, the scope of errors that will be included in the first CAIS report card, and reporting a unique CCID for foreign CAT Customers. The Working Group reviewed a response from FINRA CAT to an FIF member relating to the January 2023 report cards. The Working Group reviewed recently updated FAQs Q42 (reporting the fdidDate), Q51 (reporting the roleStartDate), and Q50 (reporting the Global Intermediary Identification Number), and new FAQ Q64 (reporting the accountType). The Working Group reviewed feedback from FINRA CAT on: Inconsistency Code 30003 (Inconsistent data for EIN); reporting the fdidEndReason, ltidEndReason and roleEndReason; CAIS compliance error rate calculations; reporting a QI-EIN, WP-EIN or WT-EIN; the Compliance submission status for the Identifiers file; Table 16: Feedback and Error Correction Availability; FDIDs with more than 100 CAT Customers; the RIC and BD customerType values for Legal Entities; addresses that exceed 160 characters; and reporting addresses at the CAT Customer level.
Eduard Kotlyar