11 April, 2022
Working Group Update 4/11/22
11 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. The Working Group also discussed other issues identified by FIF members relating to the SEC’s recent rule proposal on Short Position and Short Activity Reporting by Institutional Investment Managers.
- CAT Monthly Update Working Group Call. 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 reviewed draft FIF member comments and questions for FINRA CAT relating to scheduled linkage processing in the CAT production mirror environment, the new deskOrderID proposed by FINRA CAT, the new requirement to report the underlying instrument for a multi-leg order, and the new CAT Transaction Reporting Error Codes relating to missing and invalid FDIDs. FIF submitted these comments and questions to FINRA CAT. The Working Group reviewed issues and questions from FIF members relating to RFQ and IOI scenarios and errors caused by the CAT system. The Working Group discussed the Executed Share Model for CAT funding proposed by the CAT Operating Committee. The Working Group continued its discussion of the current exemptions for certain verbal quotes and orders that are scheduled to expire on July 31, 2023.
- FIF CAT CAIS Working Group. The CAT CAIS Working Group discussed issues and questions from FIF members relating to the length of the address fields, CAIS reporting by clearing firms and CAIS reporting by customers of foreign broker-dealers, including foreign affiliates. The Working Group reviewed new FAQ Q58 relating to the UNPARSED firstName value being introduced by FINRA CAT. The Working Group reviewed planned Technical Specifications updates relating to the foreignTIDType field, including the new OTHGOVT foreignTIDType value and additional guidance issued relating to the NATIONALID foreignTIDType value. The Working Group discussed new CAT Transaction Reporting Error Codes relating to invalid and missing FDIDs. The Working Group discussed draft comments and questions for FINRA CAT relating to foreignTIDType values, hashed SSNs, the length of the address line fields and the hasDiscretion field. The Working Group reviewed applicable guidance from the CAT adopting release relating to reporting for customers of foreign affiliates. The Working Group discussed significant challenges with CAIS CCID compliance to incorporate into the exemptive request letter relating to Authorized Traders. The Working Group discussed inter-firm testing on Material Inconsistencies.
Eduard Kotlyar