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18 July, 2022

Working Group Update 7/18/2022

18 July, 2022
  • OTC Options Reporting Working Group. This group held its first call to discuss FINRA Regulatory Notice 22-14, “OTC Options Reporting: FINRA Requests Comment on Proposed Trade Reporting Requirements for Over-The-Counter Options Transactions”.
  • Rule 605 Working Group. The Rule 605 Working Group discussed recent statements by SEC Chair Gensler on the potential expansion of Rule 605 reporting and next steps for FIF.
  • Rule 606 Working Group. The Rule 606 Working Group continued its discussion of Rule 606 reporting of held and not held orders and the SEC’s recent FAQ updates on Rule 606 reporting for fractional share orders. 
  • Back Office Committee. The FIF Back Office Committee reviewed applicable FICC, DTC, NSCC, SEC, MSRB, OCC, IRS and FINRA updates during the past month. Please find the Agenda here. 
  • FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed the July 8, 2022 SEC Exemptive Order that extended the compliance date for reporting port settings and linkage of representative and customer orders for unlinked systems. The Working Group discussed the reporting of route modification events to CAT when the only CAT-reportable field that changes is the routedOrderID. The Working Group discussed new Error Codes 2227 and 2228 that were introduced with the most recent CAT Transaction Reporting release.
  • FIF CAT CAIS Working Group. The CAIS Working Group discussed CAT Alert – 2022-01, “Full CAIS Reporting Timeline and Interim Reporting Obligations”, which was published by FINRA CAT on July 12, 2022. The Working Group reviewed and updated a draft letter from FIF to the CAT Operating Committee relating to Full CAIS implementation. FIF submitted this letter.