01 August, 2022
Working Group Update 8/1/2022
01 August, 2022
- FIF Rule 605 Working Group. The Rule 605 Working Group reviewed a draft letter to the Director of the SEC’s Division of Trading and Markets relating to remarks by SEC Chair Gensler on the potential expansion of Rule 605 reporting.
- FIF OTC Options Reporting Working Group. The OTC Options Reporting Working Group continued its discussion of FINRA Regulatory Notice 22-14, “OTC Options Reporting: FINRA Requests Comment on Proposed Trade Reporting Requirements for Over-The-Counter Options Transactions”.
- FIF Data and Technology Committee. The FIF Data and Technology Committee reviewed capacity, latency and volume data for the prior month for the equity, options, currency, crypto and futures markets. Please find the meeting materials here and the full capacity report here.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group reviewed draft comments and questions for FINRA CAT relating to the reporting of the accountHolderType value for broker-dealers and reporting responses to RFQs after July 31, 2023. The Working Group discussed issues and questions from FIF members relating to CAT reporting for a mark-up and mark-down scenario. FIF submitted this to FINRA. The Working Group discussed CAT reporting for a scenario involving internal quote messages executed against a customer order. The Working Group reviewed FIF’s submission to FINRA CAT of order route scenarios where the routedOrderID is the only CAT reportable value that changes. The Working Group discussed a request from FINRA CAT for industry feedback relating to clock synchronization and electronic timestamp increments. The Working Group discussed guidance from FINRA CAT relating to the atsDisplayInd field.
- FIF CAT CAIS Working Group. The CAIS Working Group discussed issues, questions and updates from FIF members relating to the following: FDID Refresh Report files; submitting a CAIS record that is the same as the prior CAIS record; CAIS Reporting Scenario 3.4.3 (Replacing Legal Change in EIN); the process for a triggering firm to resolve a Material Inconsistency; reporting an account held by a member of an employee’s household; third-party sources for the RIC customerType value; 36-month letter reconfirmations; and reporting for DVP accounts that do not have settlement instructions. The Working Group discussed recent updates from FINRA CAT relating to reporting for a foreign trust or foreign estate that does not have a valid CAIS identifier, the maximum number of CAT Customers for a single FDID, and the request from FIF that the regulators removed the fdidEndReason, roleEndReason and ltidEndReason fields. The Working Group discussed changes to the CAIS validation process proposed by FINRA CAT. In addition to the regularly scheduled Wednesday and Friday CAIS calls, the CAIS Working Group held an additional call this week that was focused on CAIS reporting for institutional accounts.
Eduard Kotlyar