27 September, 2021
Working Group Updates
27 September, 2021
- FIF Short Sales/Reg SHO/Short Interest Reporting. The FIF Short Sales/Reg SHO/Short Interest Reporting Working Group reviewed and made final edits to the draft FIF comment letter on FINRA Regulatory Notice 21-19, “FINRA Requests Comment on Short Interest Position Reporting Enhancements and Other Changes Related to Short Sale Reporting”. FIF will submit this comment letter on September 29, 2021. The Working Group also discussed draft requests for interpretive guidance relating to Short Interest Reporting for error scenarios. The Working Group also discussed Reg SHO compliance when firms trade as riskless principal.
- FIF Back Office Committee. The Back Office Committee reviewed applicable FICC, DTC, NSCC, SEC, MSRB, OCC, IRS and FINRA updates during the past month. The Committee discussed a question raised by an FIF member relating to Section 31 fees.
- FIF CAT Tech Specs Working Group. The CAT Tech Specs Working Group reviewed responses from FINRA CAT to the previously-submitted FIF member comments and questions on the following topics: reporting a bond swap negotiated through a broker’s broker; reporting request events for sponsored broker workflows; rejections of route cancel requests; the LCE handlingInstructions value; reporting multiple cancel requests for a single orderID; the pairedOrderID field; and mass cancel scenarios. The Working Group continued discussion of the YE representativeInd value and requesting an extension of the relief previously granted by the SEC. The Working Group reviewed draft comments and questions for FINRA CAT relating to the CAT reporting requirements for a proprietary trading firm, CAT reporting obligations for sponsored access, and the requirement to report New Quote events for quotes originated prior to Phase 2d. The Working Group discussed issues and questions from FIF members relating to the following: reporting for RFQ responses sent through an RFQ platform; reporting the multiLegInd field; reporting rejected requests; and adding the deptType field to MLOA events. The Working Group reviewed new and updated FAQs from the SROs relating to: IOIs and RFQs; reporting NBBO information; account transfers; reporting the requestTimestamp on modify and cancel events; and reporting the accountHolderType for advised accounts.
- FIF CAT CAIS Working Group. The CAT CAIS Working Group reviewed new CAIS FAQs on populating the end date when an event triggers closure of an account and account transfers. The Working Group discussed issues and questions from FIF members relating to clearing firm reporting of trading authorizations, reporting the “ein” field, the requirement for clearing firms to submit a separate CAIS file for each correspondent firm, and the requirement for a clearing firm to obtain CAIS data for a prime broker’s customer. The Working Group reviewed draft comments and questions for FINRA CAT relating to foreign identifiers that are not CAIS-permitted identifiers, confirming accuracy in response to a Material Inconsistency, the conditions that will trigger each type of Material Inconsistency, the process for resolving a Material Inconsistency, and recurrence of a Material Inconsistency that has been resolved.
Eduard Kotlyar