10 January, 2022
Working Group Update 1/10/2022
10 January, 2022
- FIF Rule 606 Working Group. The Rule 606 Working Group discussed recent feedback from the SEC staff relating to Rule 606 reporting for options and reporting for fractional shares.
- FIF Securities Lending Transparency Working Group. The Securities Lending Transparency Working Group continued its review of the SEC’s November 18 rule proposal to create a new reporting system for securities loans.
- 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 CAIS Working Group. The CAT CAIS Working Group reviewed the FIF survey request on reporting addresses at the CAT Customer level for accounts with multiple Beneficial Owners and reporting CAIS data for Authorized Traders. The Working Group reviewed responses from FINRA CAT on the following topics: CAT Customers with different tidType and tidValue for different CAT Customer records; reporting addresses of interested parties; FDIDs that are ended and reestablished; the scenario where a firm does not have an approved CAIS identifier for a foreign person; CAIS reporting for minors; discovering that a previously reported identifier is invalid; and reporting the EMPLOYEE customerType value. The Working Group discussed a question from an FIF member on reporting the same account holder with multiple FDIDs. The Working Group reviewed draft FIF member comments and questions for FINRA CAT on the following topics: Customer Identification Program requirements; various Error Codes; the requirement for a consistent identifier for foreign CAT Customers; and the value of FOR in the primeBrokerID and bankDepositoryID fields. FIF submitted these comments and questions to FINRA CAT. The Working Group reviewed and edited a response to FINRA CAT relating to mass transfers. The Working Group continued its review of the December 17, 2021 updates to the CAIS Technical Specifications.
- FIF CAT Transaction Reporting Working Group. The FIF CAT Transaction Reporting Working Group discussed various Phase 2d production issues raised by members, including linkage errors with options floor brokers, false positives generated by the CAT system, and errors generated when a DAY order is modified to a GTC and there are subsequent order events on a later date. The Working Group reviewed issues and questions raised by FIF members relating to the following: the scenario where one side reports a modification where the only CAT-reportable data that changes is the routedOrderID and eventTimestamp and the other party does not report that event; and required changes for 2022. The Working Group reviewed the December 20, 2021 updates to the CAT Transaction Reporting Technical Specifications.
Eduard Kotlyar