26 April, 2021
Working Group Update 4/26/2021
26 April, 2021
- FIF CAT Committee and Tech Specs Working Group. The FIF Working Group discussed issues and questions from FIF members relating to reporting of commission adjustments that change the allocationID, accountHolderType for IDQS quoting, repairing or correcting Phase 2a/2b submissions after the Phase 2c live date, and reporting the solicitationFlag for multiple IMIDs within the same legal entity. The Working Group discussed the recent FINRA update relating to OATS retirement. The CAT Committee discussed the CAT Operating Committee’s revised funding proposal, issues relating to the CAT Phase 2c go-live date on April 26, 2021, the rescheduling of the FINRA CAT internal DR failover test from the weekend of April 30 to the weekend of May 14, OAT retirement, and changes to the Technical Specifications and Reporting Scenarios relating to the reporting of route modifications and cancels.
- FIF CAT CAIS Working Group. The CAT CAIS Working Group discussed issues relating to the go-live of Phase 2c on April 26. The Working Group reviewed and updated the draft response to the Plan Participant survey relating to Authorized Traders. The Working Group reviewed recently updated FAQs relating to the start dates for reporting to CAIS for each phase, requirements for when an LTID is reportable, reporting multiple addresses to CAIS, reporting addresses at the Account and Customer levels, permissible circumstances for changing FDIDs, the requirement for different vendors to report the same FDID for the same account, start dates for FDID reporting, and changes to FDIDs prior to full CAIS reporting. The Working Group reviewed updates to the CAIS LTID Phase Technical Specifications.
- Back Office Committee. Please find April's Back Office Committee Agenda here. The spotlight presentation this month was held as a seperate call on April 15th, where members of the Cadwalader law firm came on to discuss the new FINRA margin regulatory notices.
- Rule 606 Working Group. On April 21, 2021, FIF and the Co-Chairs of the FIF Rule 606 Working Group participated on a call with the SEC staff relating to the SEC’s required review of the Rule 606 de minimis exceptions.
Eduard Kotlyar