22 February, 2022
Working Group Update 2/22/2022
22 February, 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 Patrick Barthel of DTCC, who discussed DTC’s new automated process for submitting instructions for voluntary corporate actions in ISO 20022 format. Please find the committee agenda here.
- FIF Rule 606 Working Group. The Rule 606 Working Group reviewed a draft interchange report to facilitate options look-through reporting. The Working Group discussed the reporting of material aspects in Rule 606(a) order routing reports. The Working Group reviewed a recent filing by the SEC that estimates the annual costs to the industry for Rule 606 compliance.
- FIF TRACE/Fixed Income Working Group. The FIF TRACE/Fixed Income Working Group continued its review of draft FIF member comments and questions for FINRA and the Federal Reserve Board relating to the rule adopted by the FRB to expand TRACE reporting for Treasury and agency securities to certain depository institutions that are not broker-dealers. FIF submitted these comments and questions to FINRA and the Federal Reserve Board.
- FIF CAT CAIS Working Group. The CAT CAIS Working Group held an additional call this week to review the most recent updates to the CAT CAIS Industry Member Reporting Scenarios. The Working Group discussed CAIS reporting for financial advisors who are employees of a reporting firm. The Working Group discussed reporting CAIS role values. The Working Group reviewed survey responses from FIF members relating to identifiers for foreign CAT Customers that are not CAIS-approved identifiers. The Working Group discussed the CAT Operating Committee request for exemptive relief from the requirement for industry members to report addresses at the CAT Customer level when there are multiple beneficial owners for an account. The Working Group reviewed recent updates by FINRA CAT relating to the following: removal of the ‘CP’ and ‘OTHBKR’ customerType values for Legal Entity Customer Records; and removal of the primeBrokerID and BankDepositoryID fields and replacing those fields with a new dvpCustodianID field. The Working Group discussed scenarios where industry members expect to have reporting gaps as of July 31, 2022 and next steps on these items. The Working Group reviewed draft comments and questions for FINRA CAT relating to the following: CAIS reporting for estate accounts with a public administrator; CAIS reporting for a US entity CAT customer where an industry member has an LEI and not an EIN; the ADVISER customerType; the AUTH3RD role for a reporting firm; Reporting Scenario 4.2.2: Account Holder and Authorized Trader Who is an Employee; and the CP customerType value. The Working Group discussed recently-updated FAQs Q7 (sensitive identifiers) and Q27 (CAIS opening for production).
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed challenges with late feedback files. The Working Group reviewed a draft request for the SEC to approve the CAT Operating Committee exemptive request letters relating to error reporting and error correction timeframes. The Working Group reviewed an updated draft follow-up submission to the regulators relating to the removal of the requirement to link representative orders to customer orders for unlinked systems. The Working Group discussed the requirement to report handlingInstructions values for port level settings applicable to orders and a proposed submission by FIF relating to this issue.
Eduard Kotlyar