25 April, 2022
Working Group Update 4/25/2022
25 April, 2022
- FIF Short Sales/Reg SHO/Short Interest Reporting Working Group. The FIF Short Sales/Reg SHO/Short Interest Reporting Working Group continued its review of a draft comment letter on the SEC’s recent proposal to mandate a new buy to cover order marker. FIF intends to submits this comment letter to the SEC on April 26.
- FIF 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 meeting materials here.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group reviewed a draft FIF member survey on per employee costs relating to reporting verbal quotes to CAT. FIF sent this survey to FIF members. The Working Group reviewed draft comments and questions to FINRA CAT relating to the reporting of FLEX options and FLEX percent options. FIF submitted these comments to FINRA CAT. The Working Group continued its discussion of linkage of representative orders to customer orders, including Manning, OTC Link, price guarantee, position fill and riskless crossing scenarios.
- FIF CAT CAIS Working Group. The CAIS Working Group reviewed draft comments and questions for FINRA CAT on the new Authorized Trader Name List and the change to require firms to report firm-managed advisory accounts with a customerType of AUTHREP instead of AUTH3RD. FIF submitted these comments and questions to FINRA CAT. The Working Group discussed other changes introduced in the April 8, 2022 updates to the CAIS Technical Specifications, including additional guidance relating to the reporting of identifier changes. The Working Group discussed issues and questions from FIF members relating to the following topics: reporting the accountType value of MARGIN; reporting for Legal Entity Authorized Traders; the process for periodic customer and account information refreshes; reporting the fdidDate for affiliates; reporting when an affiliate transfers all accounts between January and July 2022; the process for deleting a CAT error; reporting for an entity with its headquarters in the US and no US tax identifier; reporting the ACCREDITED customerType value; reporting the BROKERAGE customerType value; reporting by a prime broker where the Authorized Trader is not known; account transfers to an affiliate with the same or a different CRD; character discrepancies between CAIS and books and records; and CAIS reporting for transactions involving foreign affiliates.
Eduard Kotlyar