15 August, 2022
Working Group Update 8/15/2022
15 August, 2022
- FIF OTC Options Reporting Working Group. The OTC Options Reporting Working Group reviewed the first draft of an 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 TRACE Working Group. The Working Group discussed a recent update from FINRA on TRACE reporting for Covered Depository Institutions. The Working Group reviewed a request from FINRA and the MSRB for a discussion on collecting pre-trade information for fixed income securities. The Working Group reviewed and discussed 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”, and MSRB Notice 2022-017, “Request for Comment on Transaction Reporting Obligations under MSRB Rule G-14”. These notices propose to reduce to one minute the timeframe for reporting trades in corporate, agency and muni bonds.
- FIF CAT Transaction Reporting Working Group. The Working Group reviewed draft FIF member comments and questions for FINRA CAT on reporting for notional value orders, specifying in the Technical Specifications the date that a particular future change will take effect, reporting the limit price for a mark-up, mark-down scenario, and FAQ U6 relating to allocations to DVP accounts. The Working Group discussed reporting for orders that are part of a Rule 10b5-1 plan. The Working Group provided an update on the FIF call with the SEC on August 5 relating to the reporting of port and other default settings by a routing firm.
- FIF CAT CAIS Working Group. The CAIS Working Group discussed feedback from the SEC communicated through the Plan Participants that industry members are required to report addresses at the CAT Customer level. The Working Group discussed FIF member comments and questions for FINRA CAT relating to feedback for Material Inconsistencies, the FDID Reconciliation Report and the updateNotification field. FIF submitted these comments and questions to FINRA CAT. The Working Group discussed the current status of various exemption requests relating to CAIS.
Eduard Kotlyar