21 March, 2022
Working Group Update 3/21/2022
21 March, 2022
- 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. The spotlight presenter for the meeting was Dianne O'Boyle of Symbiont, who discussed industry solutions to solve credit market risk using blockchain.
- FIF Rule 606 Working Group. The FIF Rule 606 Working Group continued its discussion of the FINRA proposal to require Rule 606-type reporting for routes in OTC equities.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group held an additional call this week to discuss the “Proposed Cost Savings and Processing Efficiencies Related to Industry Member Transaction Processing” previously presented by FINRA CAT representatives to the FIF Transaction Reporting Working Group. The Working Group reviewed and provided comment on a draft response to these proposals. The Working Group discussed issues and questions from FIF members relating to reporting pre-Phase 2d events after the Phase 2d live date, guaranteed price orders, Manning fills and fills from position, and reporting the initiator field for Internal Route events. The Working Group reviewed a draft follow-up request to FINRA CAT relating to CAT reporting of pre-IPO symbols. FIF submitted comments to FINRA CAT relating to the proposed cost savings and processing efficiencies and pre-IPO symbols.
- FIF CAT CAIS Working Group. The CAIS Working Group held an additional call this week to complete its review of the CAIS CCID Industry Member Reporting Scenarios, Version 2.2 (January 28, 2022) and Version 2.2.1 (February 4, 2022) and also to review the March 9, 2022 updates to the CAIS CCID Technical Specifications. The Working Group discussed reporting of addresses when there are multiple beneficial owners for an FDID. The Working Group discussed the CAIS requirement to report a new customerRecordID when a CAT Customer’s tidValue changes. The Working Group reviewed draft comments and questions for FINRA CAT relating to adding an optional field to the file name to allow clearing firms to identify their correspondent firms, the scenario where a decedent is named on an account, and the new CANCELLED_BY_SUPPORT submissionStatus. The Working Group reviewed recent feedback from FINRA CAT relating to reporting for CAT Customers with multiple active roles, creating separate error codes for missing and invalid data, the indirect principal scenario, and recurrence of a Material Inconsistency. The Working Group discussed issues and questions from FIF members relating to reporting the clearingBrokerID for option accounts, un-hashed reporting of EINs and closing an account with an outstanding CAIS error. The Working Group discussed the full data replacement process.
Eduard Kotlyar