18 October, 2021
Working Group Update 10/18/2021
18 October, 2021
- FIF Rule 606 Working Group. The Rule 606 Working Group discussed questions from FIF members relating to reporting for Multi-Leg orders and reporting by an introducing broker that routes all orders to its clearing firm. The Working Group reviewed a draft request for exemptive relief relating to options look-through to be submitted by FIF to the SEC. FIF submitted this request to the SEC. The Working Group commenced 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 Rule 605 Working Group. The Rule 605 Working Group continued its discussion of the SEC’s potential expansion of Rule 605 to cover options.
- FIF Cybersecurity and Compliance Working Groups. Peter Chan and Valerie Mirko of the Baker McKenzie law firm presented to the FIF Cybersecurity and Compliance Working Groups on recent SEC fines against firms for failure to protect personally identifiable information (PII) of customers. The Working Group also reviewed recent updates from CISA.
- FIF CAT Tech Specs Working Group. The CAT Working Group reviewed guidance from FINRA CAT relating to the reporting of cancel and modification request events. The Working Group reviewed comments and questions from FIF members relating to combining individual legs into a Multi-Leg order, a proposed option to link a representative order to the associated customer order in a price guarantee scenario, a proposed optional method for receiving firms to report rejections of cancel and modification requests, reporting for a system that only accepts Multi-Leg orders, and a proposed expansion of FAQ E31 relating to messages that cannot be read or parsed by the destination venue. The Working Group reviewed the October 8, 2021 updates to the Phase 2d Technical Specifications document. The Working Group reviewed responses from FINRA CAT to prior comments and questions from FINRA CAT. The Working Group reviewed updated FAQs relating to the reporting of FDIDs. The Working Group held an additional call focused on CAT Phase 2d reporting for manual option scenarios.
- FIF CAT CAIS Working Group. The CAT CAIS Working Group held an additional call this week focused on the September 21, 2021 updates to the CAIS CCID Reporting Scenarios. The Working Group reviewed the updated digest of FIF comments and questions and responses from the SROs and FINRA CAT. The Working Group reviewed the October 8, 2021 updates to the CAIS CCID Technical Specifications, including changes relating to the reporting of mass transfers, the material inconsistencies process and the requirement for clearing firms to submit separate files for each correspondent firm. The Working Group discussed challenges with reporting address information at the CAT customer level. The Working Group discussed CAIS reporting requirements for clearing firms.
Eduard Kotlyar