21 June, 2022
Working Group Update 6/21/2022
21 June, 2022
- TRACE/Fixed Income Working Group. FIF and the FIF Co-Chairs provided an update on a June 7 call with FINRA, FIF and the FIF TRACE Co-Chairs relating to TRACE reporting by Covered Depository Institutions. The Working Group discussed the May 23, 2022 rule filing by FINRA with the SEC (SR-FINRA-2022-013) to require reporting of transactions in U.S. Treasuries as soon as practicable, but no later than one hour after execution, and to require that electronic executions in U.S. Treasuries be reported to TRACE using the same time increment as recorded by the execution system for the transaction. The Working Group discussed recent guidance received by an FIF member from FINRA relating to TRACE reporting of the portfolio trade modifier for corporate bonds. The Working Group reviewed a recent vote by the MSRB to seek public comment on enhancing post-trade transparency and a recent speech by SEC Chair Gensler that included a discussion on enhancing transparency for the fixed income markets.
- FIF Rule 606 Working Group. The Rule 606 Working Group discussed the SEC’s recent FAQ updates on Rule 606 reporting for fractional share orders.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group reviewed the recent filing by the SROs of an Exemptive Request Letter Relating to Verbal Floor and Upstairs Activity. The Working Group reviewed draft FIF member comments and questions for FINRA CAT relating to the DIR handlingInstructions value, the atsDisplayInd field, adding an accountHolderType for a broker-dealer account, reporting the accountHolderType value for a foreign legal entity, and segmenting report cards by IMID. FIF submitted these comments and questions to FINRA CAT. The Working Group discussed issues and questions from FIF members relating to reporting the deskOrderID, the solicitationFlag, reporting the accountHolderType for allocations, and reporting when there is a symbol change. The Working Group discussed a draft submission on linkage of rep and customer orders.
- FIF CAT CAIS Working Group. The CAIS Working Group discussed issues and questions from FIF members relating to an account that changes its CRD but not its FDID, US customers that do not have an EIN, and CAT Customer records with the same TID and associated to the same FDID that are ended and added the same day. The Working Group reviewed and discussed updates from FINRA CAT relating to upcoming releases, the new foreignTIDType of OTHGOVT, and proposed changes to CAIS validations. The Working Group discussed submitting a letter to the CAT Operating Committee to request additional transparency relating to the planned Full CAIS live date. FIF drafted and submitted this letter.
Eduard Kotlyar