20 December, 2021
Working Group Update 12/20/2021
20 December, 2021
- FIF Cybersecurity and Compliance Working Groups. Alaina R. Clark, Assistant Director for Stakeholder Engagement at the Cybersecurity and Infrastructure Security Agency (CISA), presented to a joint call of the FIF Cybersecurity and Compliance Working Groups on the role and functions of CISA. CISA is an agency of the Department of Homeland Security.
- FIF Front Office Committee. The FIF Front Office Committee met to review applicable updates and notices from the SEC, FINRA, FINRA CAT and the equity and option exchanges. Please find this month's agenda here.
- FIF TRACE Working Group. The FIF TRACE Working Group continued its discussion and review of a draft comment letter on SR-FINRA-2021-030 , “Notice of Filing of Proposed Rule Change to Amend FINRA Rule 6730 to Require Members to Append Modifiers to Delayed Treasury Spot and Portfolio Trades When Reporting to TRACE.”
- FIF Securities Lending Transaction Working Group. The Securities Lending Transaction Working Group continued its discussion of the SEC’s November 18 rule proposal to create a new reporting system for securities lending.
- FIF CAT Tech Specs Working Group. The CAT Tech Specs Working Group discussed new FAQ B76 relating to reporting for mass cancels. The Working Group reviewed new Reporting Scenario 3.8.2: “Broker Receives a Partially Formed Multi-Leg Order where not all Legs are Determined when Trading Authorization is Immediately Actionable.” The Working Group discussed issues and questions from FIF members relating to the following: stats on industry wide reporting; a scenario involving an Order Route followed by a Route Cancel Request and Rejection of the Order Route; optionally reporting an unsolicited cancel or modification; and reporting the YE flag where there are no customer orders. The Working Group discussed Phase 2d production issues raised by FIF members.
- FIF CAT CAIS Working Group. The CAT CAIS Working Group discussed a recent call involving the FIF CAIS Co-Chairs, the SEC and the CAT Operating Committee relating to the reporting of addresses at the CAT Customer level and the reporting of CAIS data for Authorized Traders. The Working Group discussed announced changes to the CAIS Technical Specifications document relating to the following: the addition of DRIVERLICENSE as a foreignTIDType; validation for EINs; the addition of the AE, AA and AP regionCode values; changes to the definitions of the EMPLOYEE and ADVISER customerType values; the addition of “FOR” (for foreign) as a permitted primeBrokerID and bankDepositoryID value; updates to Table 3 relating to Customer Data Inconsistencies; and the addition of a new fdidEndReason of INACTIVE. The Working Group reviewed a draft FIF CAIS survey request relating to reporting addresses at the CAT Customer level for accounts with multiple Beneficial Owners and reporting CAIS data for Authorized Traders. The Working Group discussed draft FIF member comments and questions for FINRA CAT relating to the following: creating separate error codes for missing and invalid data; Material Inconsistences prior to the Full CAIS live date; the requirement to remove account numbers from CAIS records; reporting for Indirect principal scenario; and reporting for prime broker scenarios. The Working Group discussed issues and questions from FIF members relating to various CAIS Error Codes.
Eduard Kotlyar