14 February, 2022
Working Group Update 2/14/2022
14 February, 2022
- FIF Rule 606 Working Group. The Rule 606 Working Group reviewed a draft interchange report to facilitate options look-through reporting for future periods, provided an update on recent discussions between an FIF member and the SEC staff relating to Rule 606(a) and 606(b)(3) reporting for principal value orders that involve fractional shares, and discussed Rule 606(a) reporting for complex orders.
- 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 CAT CAIS Working Group. FIF members had a call with FINRA CAT to discuss CAIS reporting for the primeBrokerID and bankDepositoryID fields. The Working Group reviewed the outcome of this discussion. The Working Group discussed proposed exemptive requests relating to CAIS. The Working Group discussed comments and questions for FINRA CAT on the following topics: the description of the fdidCustomerList in the Technical Specifications; the definitions of Natural Person and Legal Entity in the Glossary of the Technical Specifications; the description of the Transformed Identifiers File in the Technical Specifications; reporting for Commodity Trading Advisors and state-registered investment advisers; CAIS system validation of FDIDs against CAIS data; CAIS reporting for restricted accounts; cybersecurity and data protection controls for the CAIS test environment; reporting the CP and OTHBRK customerType values for Legal Entity CAT Customers; CAIS reporting for unparsed name fields; and reporting the AUTHREP and TRDHOLDER fields. FIF submitted these comments and questions to FINRA CAT on behalf of the Working Group.
- FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed challenges with the current feedback delays and the T+3 at 8 am timeframe for resolving linkage errors. The Working Group reviewed the temporary exemptive relief granted by the SEC to the SROs relating to timelines for providing error correction feedback and previously-submitted requests for permanent exemptive relief submitted by the CAT Operating Committee relating to timelines for providing error correction feedback and resolving linkage errors. The Working Group reviewed a draft comment for FINRA CAT relating to the reporting of rejected routes, route modification requests and route cancel requests. The Working Group discussed whether Release 1 items can be submitted prior to March 21, 2022. The Working Group continued its discussion of linkage of representative orders for unlinked systems.
Eduard Kotlyar