14 March, 2022
Working Group Update 3/14/2022
14 March, 2022
- FIF Short Sales/Reg SHO/Short Interest Reporting Working Group. The Short Sales/Reg SHO/Short Interest Reporting Working Group discussed the recent SEC rule proposal to create a new short interest reporting requirement, mandate a new buy to cover order marker, and require new CAT reporting modifiers for buy to cover orders and short sales that rely on the bona fide market making exception.
- FIF Compliance Working Group. Satish Kini and Robert Dura from the Debevoise law firm provided an update on the recent OFAC sanctions against Russia, including recent Directives under Executive Order 14024. Representatives from the New York City Bar Association Compliance Committee discussed a report by the Compliance Committee of the New York City Bar Association that details concerns about compliance officer liability and calls on regulators to provide limitations and guidance on when a compliance officer should be charged.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group held an additional call this week to focus on linkage of customer and representative orders for unlinked systems. During the regularly scheduled Working Group call this week, representatives from FINRA CAT presented to the Working Group on “Proposed Cost Savings and Processing Efficiencies Related to Industry Member Transaction Processing” and solicited feedback on these proposals from FIF members.
- FIF CAT CAIS Working Group. The CAIS Working Group discussed issues and questions from FIF members relating to the ACCREDITED customerType, reporting for a deceased person where a firm does not have an SSN, legal entities reported with an SSN, clearing firm file names for correspondent firms, challenges with identifying active accounts, and replacing the FDID Customer Records when a Customer’s TID Changes. The Working Group discussed the reporting of addresses at the CAT Customer level when there are multiple beneficial owners for an account.
Eduard Kotlyar