23 May, 2022
Working Group Update 5/23/2022
23 May, 2022
- FIF Compliance Working Group Call Focused on Trade Surveillance. The Compliance Working Group hosted a call focused on trade surveillance issues.
- FIF Back Office Committee. The Back Office Committee reviewed applicable FICC, DTC, NSCC, SEC, MSRB, OCC, IRS and FINRA updates during the past month. Please find the May agenda here.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group reviewed the May 16, 2022 updates to the Phase 2d Technical Specifications. The Working Group discussed the new Proposed CAT NMS Amendment providing for an Alternative Funding Model, submitted by the CAT Operating Committee to the SEC on May 13, 2022. The Working Group reviewed feedback from FINRA CAT on comments and questions submitted by FIF members relating to FLEX and FLEX percent options, scheduled linkage processing in the CAT production mirror environment, reporting the underlying instrument for a multi-leg order event, and new Error Codes 3701 through 3710 (missing or invalid FDID).
- FIF CAT CAIS Working Group. The CAT CAIS Working Group discussed a letter relating to the Full CAIS Live Date sent by FIF to the CAT Operating Committee and next steps. The Working Group reviewed feedback from FINRA CAT on comments and questions previously submitted by FIF members relating to proposed enhancements to the ingestion feedback process, reporting of the AUTHREP and AUTH3RD role values, addresses that exceed 160 characters, the Authorized Trader Name List, the foreignTIDType value of DRIVERLICENSE, GIINs, scenarios where a decedent is named on an account, CAIS reporting by a correspondent firm for institutional accounts, estate accounts with a public administrator, a US entity CAT Customer where a firm has an LEI and not an EIN, and reporting Mass Transfers. The Working Group discussed CAIS rejections for reporting an FDID with more than 100 CAT Customers. The Working Group continued its review of the CAIS Reporting Scenarios. The Working Group reviewed new and recently updated FAQs Q59 (FDIDs that are in scope for the CAIS CCID Phase), Q60 (not held orders), Q61 (industry member executing standing instructions on an account), Q62 (clearing firm replicating a correspondent firm attribute), and T7 (reporting of AUTHREP and AUTH3RD roles). The Working Group discussed issues and questions from FIF members relating to validation between accountHolderType values (for CAT Transaction Reporting) and accountType values (for CAIS), upon-death beneficiaries, foreign entity accounts where a firm only has an identifier for an associated Natural Person, reporting for an FDID with multiple addresses, third-party software that generates automatic trades, and cross-validations between CAT Transaction Reporting and CAIS.
Eduard Kotlyar