06 June, 2022
Working Group Update 6/6/2022
06 June, 2022
- TRACE/Fixed Income Working Group. The FIF TRACE/Fixed Income Working Group reviewed a draft comment letter on the recent FINRA rule filing with the SEC to expand TRACE reporting to cover transactions in US dollar denominated foreign sovereign bonds. The Working Group discussed recent FAQ updates from FINRA relating to TRACE reporting by covered depository institutions, which takes effect on September 1, 2022.
- Securities Lending Transparency Working Group. The Securities Lending Transparency Working Group discussed a request that FIF received from SEC staff members to discuss the comment letter on the SEC’s Securities Lending Transparency rule proposal that FIF submitted on January 19, 2022.
- CAT Monthly Update Working Group. The CAT Monthly Update Working Group reviewed guidance and updates from the SROs and FINRA CAT on CAT transaction reporting and CAT CAIS reporting during the prior month. The Working Group also reviewed the current areas of focus for FIF members and the current open issues for CAT transaction reporting and CAT CAIS reporting.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed submissions to the CAT Transaction Reporting system to correct historical errors, the FINRA rapid remediation process and other FINRA inquiries related to historical CAT reporting. The Working Group discussed the scenario where a CAIS validation fails and the reporting firm corrects the error in CAIS after T+3. The Working Group continued its discussion of the Executed Share Model for CAT funding proposed by the CAT Operating Committee with a focus by the Working Group on how share volume would be determined by the regulators.
- FIF CAT CAIS Working Group. The CAIS Working Group provided an update on feedback from the SEC relating to the exemptive request for authorized traders. The Working Group discussed how this impacts reporting of the Authorized Trader Names List. The Working Group discussed the May 27 FINRA CAT announcement to delay the Full CAIS live date. The Working Group provided an update on a call with the SEC to discuss testing challenges that firms have faced in preparing for the Full CAIS live date. The Working Group discussed issues and questions from FIF members relating to submission file status, feedback processing and reporting the DVPCustodianID when delivery instructions have been removed from an inactive account. The Working Group discussed updates from FINRA CAT on the June 1 CAIS Industry Testing Checkpoint Call. The Working Group discussed potential conflicts with the planned migration of options to NYSE Pillar on July 11, 2022. The Working Group reviewed draft FIF member comments and questions for FINRA CAT on CAIS compliance error rate calculations, a scenario involving an FDID with two CAT Customers with different names, different LEIs and the same EIN, discrepancies in the CAIS record count, reporting for CAT Customers that have an EIN and also have a QI-EIN, WP-EIN or WT-EIN, and updating CAIS date fields when an account is reopened.
Eduard Kotlyar