10 May, 2021
Working Group Update 5/10/2021
10 May, 2021
- FIF CAT Tech Specs Working Group and CAT Committee. The CAT Tech Specs Working Group discussed issues and questions from FIF members relating to the following: the scenario where the only CAT-reportable change is the routedOrderID; challenges with reporting the pairedOrderID for the manual route of option orders to floor brokers; and customer accommodation scenarios for options. The Working Group reviewed a proposal to FINRA CAT relating to customer accommodation scenarios. FIF submitted this proposal to FINRA CAT. The FIF CAT Committee reviewed the comment letter filed by the CAT Operating Committee that provided additional information relating to the Operating Committee’s Revised Funding Model proposal. The FIF CAT Committee discussed the transition to Phase 2c and new open issues identified by FINRA CAT to be resolved on May 10. The Committee reviewed updated FAQs relating to the reporting of tied orders where a net price is not available, the reporting of accountHolderType for accounts that include market making and non-market making activity, reporting for equity allocations processed prior to the Phase 2c go-live date and options allocations processed prior to the Phase 2d go-live date, and the reporting of settlementDate for Allocation events involving when-issued securities. The Committee discussed OATS retirement issues. The Committee discussed the joint response submitted by SIFMA and FIF to the Plan Participants survey relating to individuals associated with Authorized Traders that are entities. The Committee discussed CAT Alert 2021-02, Standards for Completing the Customer and Account Reporting Disclosure Form.
- FIF CAT CAIS Working Group. The CAIS Working Group reviewed draft changes to the Full CAIS Reporting Technical Specifications provided by FINRA CAT. The Working Group reviewed the previous comments and questions submitted by FIF to FINRA CAT relating to CAIS and identified the open and closed items. The Working Group discussed comments and questions from FIF members relating to CAIS reporting for account title changes, the time lag between the Phase 2d requirement to report TIDType and the full CAIS requirement to report TIDType, FDIDs for CAT Customers with more than four account addresses, the requirement to report addresses “associated with an account”, the reporting of addresses that are “reasonably available”, permitting firms to submit CAIS records with incomplete data, the reporting of the correspondentCRD field, entities where firms can record either an ein or an SSN, the permitted range of ASCII values, and validations relating to the reporting of a TID associated to multiple customer records.
- Rule 606 Working Group. The Rule 606 Working Group provided an update on a recent discussion with the SEC staff relating to the Rule 606 de minimis exceptions. The Working Group discussed issues and questions raised by FIF members relating to identification of the customer in an RIA scenario, aggregated customer orders and options look-through.
Eduard Kotlyar