31 May, 2021
Working Group Update 6/1/2021
31 May, 2021
- FIF CAT Tech Specs Working Group and CAT Committee. The CAT Tech Specs Working Group reviewed recent FAQ updates relating to CAT orders received or originated but not executed prior to the date an Industry Member is required to begin reporting data to CAT, accountHolderType of “O”, reporting cash orders, and clearing firms reporting allocations to average price accounts of an Introducing Broker that may be exclusively for a specific client of the Introducing Broker. The Working Group discussed the most recent update from FINRA relating to OATS retirement. The Working Group reviewed and discussed additional responses from FIF members relating to reporting Route Modification events to CAT when the only CAT-reportable field that changes is the routedOrderID. FIF submitted a proposal to FINRA CAT on this issue. The Working Group discussed representative order Reporting Scenarios, including Guaranteed VWAP and Manning Rule scenarios. The Working Group discussed issues and questions from FIF members relating to the requirement to report quantity for Automated Investment Plan orders, the requirement in FAQ C8 to report “solicitationFlag = true” for any response to a “specific invitation to take the contra-side of an existing order”, and reporting options allocations. The Working Group reviewed the FINRA CAT May 21, 2021 updates to the Phase 2c and 2d Reporting Scenarios documents.
- FIF CAT CAIS Working Group. The CAT CAIS Working Group reviewed draft comments and questions for FINRA CAT relating to legal entities with a tidType of “SSN/ITIN”, Relationship FDIDs, CAIS reporting for deactivated and reactivated accounts, and CAIS reporting for recently-opened accounts. FIF submitted these comments and questions to FINRA CAT. Working Group participants discussed whether they will be reporting all active accounts to CAIS or limit reporting to only those accounts that have CAT reportable activity.
- Front Office Committee. The Committee reviewed recent rule filings and other notifications by the SEC, FINRA, the exchanges and other SROs. Please find this month's agenda here.
- Rule 605 Working Group. The Working Group reviewed responses from FIF members to a recent FIF survey about various Rule 605-related proposals. The Working Group discussed the recent GameStop hearing, including statements by SEC Chairman Gary Gensler and FINRA CEO Robert Cook. The Working Group discussed next steps.
- Tax Information Reporting Working Group. The group's Refinitiv co-chairs presented this month on Tax Reconciliations: Form 945 and Form 1042, Secure Act 2.0, Section 1446(f), and Form and Guidance Updates
- Data and Technology Committee. Kevin Tyrrell of the New York Stock Exchange presented to the Data and Technology Committee on recent trends relating to opening and closing auctions. Please find the Meeting Materials here and the expanded Capacity Statistics Deck here.
- Reg SHO Working Group. The Reg SHO Working Group discussed specific Reg SHO issues and questions raised by FIF members relating to locate and close-out requirements. The Working Group discussed potential comments and questions to present to the SEC staff
Eduard Kotlyar