07 June, 2021
Working Group Update 6/7/2021
07 June, 2021
- Rule 606 Working Group. The Rule 606 Working Group discussed issues and questions raised by FIF members relating to orders sent directly to an ATS, ATS matching with a single market maker, Rule 606(b)(3) requests from sub-accounts, and look-through for Rule 606(a) options reporting.
- Market Trends in Total Return Swaps vs Securities Lending. Josh Galper of Finadium presented to the Front and Back Office Committees on market trends in total return swaps vs. securities lending, including the impact of Archegos.
- FIF CAT Tech Specs Working Group and CAT Committee. The CAT Tech Specs Working Group discussed complex option orders where different legs have different FDIDs. The Working Group discussed comments and questions from FIF members relating to allocations to broker-dealer accounts, options allocations, manual responses to options solicitations, and Guaranteed VWAP scenarios. The CAT Committee provided an update on the CAT Revised Funding Model proposal. The CAT Committee reviewed updates to the Technical Specifications and Reporting Scenarios during the month of May. The CAT Committee provided an update on OATS retirement. The CAT Committee reviewed guidance provided by FINRA CAT during May relating to reporting allocation events for corporate buy-backs, reporting the DISQ handlingInstruction, and allocation reporting for symbol change scenarios. The CAT Committee reviewed significant open issues on CAT CAIS and CAT transaction reporting.
- FIF CAT CAIS Working Group. The CAT CAIS Working Group reviewed responses from FIF members to an FIF survey on whether firms plan to report all active accounts to CAIS (and potentially over-report) or limit reporting to only those accounts that had CAT-reportable activity. The Working Group reviewed new and recently updated FAQs relating to sensitive identifiers, reporting the customerType for a CAT Customer who has a US Taxpayer Identification Number but a foreign address or foreign identification/passport or is otherwise identified as foreign by the Industry Member, and reporting the ADVISER customerType. The Working Group reviewed issues and questions raised by FIF members relating to limited information available for sub-accounts, the definition of “associated person” in the description of the EMPLOYEE customerType, and an FIF member’s analysis of the reporting for Relationship FDIDs.
Eduard Kotlyar