08 November, 2021
Working Group Updates
08 November, 2021
- FIF Rule 606 Working Group. The Rule 606 Working Group continued its discussion of 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.”
- 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 FINRA inquires relating to newOrderFDID not being provided in Allocation events. The Working Group discussed issues and questions from FIF members relating to the following: accountHolderType of ‘A’ (Institutional Customer); the netPrice field; the Participant specifications on reporting rejected order, route, modification and cancel request events; and reporting for FLEX options. The Working Group reviewed draft FIF member comments and questions for FINRA CAT relating to pre-IPO symbols (FAQ A33) and the CMPX handlingInstructions value. The Working Group discussed the following CAT Transaction Reporting Exemptions that expire on July 31, 2023: Reporting of Port Level Settings Applicable to Orders; Lifecycle Linkage Between Customer Orders and “Representative” Orders; Unlisted IDQS quotes; Manual RFQ responses; and New Order key for Internal Route events. The Working Group reviewed a draft FIF member survey on Lifecycle Linkage Between Customer Orders and “Representative” Orders. The Working Group reviewed instructions from FINRA CAT on exporting the FAQs.
- FIF CAT CAIS Working Group. The CAT CAIS Working Group continued its review and discussion of the most recent updates to the CAIS Reporting Scenarios. The CAIS Working Group discussed issues and questions from FIF members relating to reporting IRA Qualified Plan trustees, reporting attributes and values when industry members do not have the data, and reporting the accountType of INSTITUTION. The Working Group reviewed a response from FINRA CAT to an FIF member on why CAT processes TID errors as Warnings. The Working Group reviewed draft FIF member comments and questions for FINRA CAT on the following: scenarios where firms do not have a valid CAIS identifier; the EMPLOYEE customerType value; the Glossary definition of Legal Entity; Minor Inconsistencies; and Reporting Scenarios 2.5.2 (Clearing Firm & Introducing Broker Reporting Custodied Account) and 2.6.1 (FDID with One LTID). [this section to be updated after today’s CAIS call]
Eduard Kotlyar