06 December, 2021
Working Group Update 12/6/2021
06 December, 2021
- FIF Securities Lending Transparency Working Group. The Securities Lending Transparency Working Group discussed the SEC’s recent rule proposal to create a new regulatory reporting system to enhance transparency in the securities lending market.
- FIF TRACE Working Group. The TRACE Working Group discussed two recent filings by FINRA relating to TRACE reporting for ATS trades, delayed Treasury spot trades and portfolio trades.
- FIF Rule 606 Working Group. The Rule 606 Working Group provided final comments for the FIF comment letter on FINRA Regulatory Notice 21-35, “FINRA Requests Comment on Proposed Order Routing Disclosure Requirements for OTC Equity Securities and Potential Steps to Facilitate Investor Access to Current Order Routing Disclosures for NMS Securities.” The Working Group continued its discussion of options look-through. FIF submitted supplemental information to the SEC relating to options look-through.
- FIF CAT Committee. The CAT Committee reviewed guidance and updates from the SROs on CAT transaction reporting and CAT CAIS reporting during the prior month. The CAT Committee reviewed the current areas of focus for FIF members and the current open issues for CAT transaction reporting and CAT CAIS reporting.
- FIF CAT Tech Specs Working Group. The CAT Tech Specs Working Group discussed cancel request scenarios. The Working Group reviewed responses from FIF members to an FIF survey on linkage between rep and customer orders and a draft FIF submission to FINRA CAT. FIF submitted comments to FINRA CAT on this issue. The Working Group discussed other changes that are scheduled to take effect on July 31, 2023, including reporting of handling instructions that are incorporated in port settings and reporting of manual RFQ responses. The Working Group reviewed an updated FAQ on the reporting of the cancelFlag and cancelTimestamp on Option Trade events. The Working Group discussed draft FIF member comments and questions for FINRA CAT on multiple partial cancels within the same time increment and linking a cancel event to a prior route modify request that is subsequently rejected by the receiving party. FIF submitted these comments to FINRA CAT.
- FIF CAT CAIS Working Group. FIF updated the Working Group on an FIF discussion with FINRA CAT relating to the reporting of mass transfer scenarios. The Working Group discussed follow-up questions from FINRA CAT on this topic. The Working Group discussed issues and questions from FIF members relating to reporting all customer accounts to CAIS (including accounts that do not have CAT-reportable activity), Full CAIS error management processes, CAIS reporting for deceased natural persons, FINRA CAT validation of account names, challenges with reporting branchOfficeCRD values, reporting a beneficial owner when the order placer is a regulated entity, reporting an SSN or TIN with all zeros, reporting for unresponsive legacy clients, reporting military addresses, and daily resubmission of all FDIDs vs. only submitting changed FDIDs. The Working Group discussed new FAQ Q55 relating to Industry Member requirements upon receipt of a Material Inconsistencies notification. The Working Group reviewed a draft response to FINRA CAT on the reporting of mass transfer scenarios. The Working Group discussed a request from the SROs and FINRA CAT for additional detail relating to scenarios where a firm is unable to report all required account data to CAIS at the time an account first has CAT-reportable activity.
Eduard Kotlyar