22 February, 2021
Working Group Update 2/22/2021
22 February, 2021
- FIF CAT Tech Specs Working Group. The CAT Tech Specs Working Group reviewed and discussed new FAQ B71 relating to the TTS, TTF, TTO, TTU, FUT, TTSO, OPT and CMPX handlingInstructions. The Working Group reviewed and discussed the FINRA CAT Technical Specification Working Group call held on February 16. The Working Group continued its review of the Phase 2d CAT Technical Specifications and Reporting Scenario documents issued by FINRA CAT on February 5, including changes relating to route modification and cancel events, order identifiers for internal route events, the reporting of the number of legs for multi-leg orders and the OS fulfillmentLinkType. The Working Group also discussed the new Option Trade event. FIF submitted to FINRA CAT FIF member feedback relating to unsolicited cancels. Chris Bok of OTC Markets reviewed the Phase 2d reporting requirements for transactions involving an IDQS (inter-dealer quotation system).
- FIF CAT CAIS Working Group. The CAT CAIS Working Group discussed various issues relating to the reporting of customer and FDID start and end dates, retiring the accountHolderType from CAT transaction reporting when full CAIS reporting goes live, removing region codes, challenges with limited CAIS feedback, issues relating to the reporting of primeBrokerID and bankDepositoryID, and CAIS certification issues. On February 19 FIF CAT CAIS Working Group members participated on a call with FINRA CAT and the Plan Participants to discuss CAIS reporting for non-US persons.
- FIF Rule 606 Working Group. As a follow-up to the most recent Working Group call, FIF submitted to the SEC staff a request for guidance relating to the Rule 605 reporting of not held IOC orders. This is a follow-up to recent guidance that FIF obtained from the SEC staff relating to the Rule 606 reporting for these orders.
- FIF TRACE Working Group. The Working Group reviewed and made final revisions to the FIF comment letter on FINRA’s Regulatory Notice relating to Enhancements to TRACE Reporting for U.S. Treasury Securities. FIF submitted the comment letter on February 19. The Working Group also discussed a rule proposal by the Federal Reserve to expand TRACE reporting for Treasuries and agencies to certain depository institutions and the potential impact on broker-dealers that currently report to TRACE. The Working Group reviewed and provided input to the current draft FIF comment letter on this rule proposal. The Working Group also discussed the Recommendation Regarding Defining “Electronic Trading” for Regulatory Purposes issued by the Fixed Income Market Structure Advisory Committee (FIMSAC) on October 5, 2020 as it relates to TRACE reporting.
- FIF Back Office Committee. On February 16, Professor James Angel of the Georgetown McDonough School of Business discussed his recommended changes to stock lending, buy-in, short sale reporting and settlement rules in response to the recent trading activity in GameStop. Find this month's agenda here.
- FIF Cybersecurity Working Group. Our last meeting was on 2/18 where we reviewed important notices from January and February including notices from CISA, NSA and the FBI.
Eduard Kotlyar