25 October, 2021
Working Group Updates 10-25-21
25 October, 2021
- FIF Rule 606 Working Group. The Rule 606 Working Group discussed 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.”
- Back Office Committee. The FIF Back Office Committee reviewed applicable FICC, DTC, NSCC, SEC, MSRB, OCC, IRS and FINRA updates during the past month.
- Firm Processes for Validating SSNs and other identifiers. In response to an FIF member request, FIF held a call this past week focused on firm processes for validating SSNs and other natural person and legal entity identifiers.
- FIF CAT Tech Specs Working Group. The CAT Tech Specs Working Group reviewed draft FIF member comments and questions for FINRA CAT relating to the following: FAQ E31 on messages that cannot be read or parsed by the destination venue; cancel and modification requests received prior to acceptance of a new order; and reporting cancelQty for full cancel after a partial execution. The Working Group discussed issues and questions from FIF members relating to Multi-Leg Orders with a net price of zero and reporting cancels for DMA and sponsored broker workflows. The Working Group continued its discussion of disconnected OMS-EMS scenarios. The Working Group reviewed updated CAT FAQs relating to FDIDs.
- FIF CAT CAIS Working Group. The CAT CAIS Working Group discussed the recent update from FINRA CAT to change the registeredRepCRD field to an optional field in all circumstances. The Working Group discussed FIF’s responses to the regulators relating to the reporting of addresses at the customer level. The Working Group reviewed draft FIF member comments and questions for FINRA CAT relating to the following: Version 2.1 of the CAIS CCID Reporting Scenarios; creating separate error codes for missing and invalid data; validation of tidValue; hierarchy of foreign identifier types; Version 2.0 r4 of the Full CAIS Technical Specifications; and addresses for interested parties. The Working Group reviewed the most recent items added to the Planned CAIS Technical Specifications updates. The Working Group discussed responses from the SROs and FINRA CAT to various prior comments and questions submitted by FIF. The Working Group discussed CAIS reporting for CAT Transaction Reporting Scenarios 6.1.3 and 6.1.5. The CAT CAIS Working Group held an additional call this week to continue the review of the most recent updates to the CAIS CCID Reporting Scenarios.
Eduard Kotlyar