07 March, 2022
Working Group Update 3/7/2022
07 March, 2022
- FIF Rule 606 Working Group. The Rule 606 Working Group continued its review of a draft FIF comment letter on the request submitted by the SEC to the Office of Management and Budget for approval of the extension of Rule 606. FIF submitted this comment letter on March 2. The Working Group discussed the FINRA proposal to require Rule 606-type reporting for routes in OTC equities.
- FIF Cybersecurity Working Group. The Cybersecurity Working Group discussed state-sponsored cybersecurity threats from Russia, the 2022 report on FINRA's examination and risk monitoring program, a 2021 year-in-review report from the NSA, and news of Chair Gensler potentially overhauling the SEC’s cyber rules.
- FIF Securities Lending Transparency Working Group. The FIF Securities Lending Transparency Working Group discussed a request from attorneys in SEC Chair Gensler’s office to engage in discussions with FIF members relating to securities lending workflows and the SEC’s recent rule proposal relating to securities lending transparency.
- FIF CAT Monthly Update Working Group. The CAT Monthly Update Working Group reviewed guidance and updates from the SROs on CAT transaction reporting and CAT CAIS reporting during the prior month. The Working Group 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 continued its discussion of FAQ K25 relating to reporting of the OPT handlingInstructions value. The Working Group reviewed draft FIF member comments and questions for FINRA CAT relating to the reporting of port level settings and ATS reporting for peg orders. The Working Group discussed questions from FIF members on late filing of pre-Phase 2d CAT data after the Phase 2d live date and reporting indicative fills. The Working Group reviewed recent amendments to the CAT NMS Plan proposed by the SEC relating to CAT reporting for “buy to cover” orders and certain short sales effected by a market maker in connection with bona-fide market making activities. FIF submitted comments to FINRA CAT relating to the reporting of port level settings, reporting linkage of customer and rep orders for unlinked scenarios, and extending the current timeframes for FINRA CAT to provide feedback and for industry members to correct CAT errors.
- FIF CAT CAIS Working Group. The CAT CAIS Working Group continued its review of the January 28 and February 4, 2022 updates to the CAT CAIS Industry Member Reporting Scenarios. The Working Group reviewed draft FIF member comments and questions for FINRA CAT relating to CAIS reporting by a correspondent firm for institutional accounts and the January 28 and February 4, 2022 updates to the Reporting Scenarios. FIF submitted these comments and questions to FINRA CAT. The Working Group discussed a draft exemption request presented by SIFMA relating to CAIS reporting for Authorized Traders. The Working Group discussed issues and questions from FIF members relating to sourcing customerType data, updates to client information, reporting the updateNotification and addressList fields, CAIS certification, clearing firm reporting for correspondent accounts, and reporting for an account that has multiple associated branch offices. The Working Group discussed a request for feedback from FINRA CAT relating to the reporting of the clearingBrokerID field.
Eduard Kotlyar