25 January, 2021
WORKING GROUP AND COMMITTEE UPDATES
25 January, 2021
- FIF CAT Tech Specs Working Group. The CAT Tech Specs Working Group discussed comments and questions for FINRA CAT relating to multi-leg scenarios, reporting of events that occur the evening prior to delisting of a symbol, Net Asset Value workflow, buy-in as agent, and the new numberOfLegs field. The Working Group completed its review and discussion of the FINRA CAT January 8 updates to Phase 2c Reporting Scenarios. The Working Group discussed issues raised by FIF members relating to the ability to report allocation amendments that do not change CAT reportable attributes and false positive errors received by firms. The Working Group reviewed updated FAQs relating to exchange for physicals transactions, reporting the initiator field for order modifications and cancels, trades priced at the Net Asset Value with no offset, CAT reporting for trade correction scenarios, OTC Link messages and booking of allocation events.
- FIF CAT CAIS Working Group. The Working Group discussed and drafted responses to the Plan Participant proposals relating to CAIS Customer and Account Types and submitted these responses to FINRA CAT. The Working Group discussed and drafted new and open items for FINRA CAT relating to CAIS and submitted these to FINRA CAT. The Working Group reviewed and discussed the updated CAIS Technical Specifications published by FINRA CAT on January 19 and drafted comments to submit to FINRA CAT.
- FIF TRACE Working Group. The TRACE Working Group reviewed and discussed FINRA’s request for comment on Enhancements to TRACE Reporting for U.S. Treasury Securities, with a focus on the FINRA proposals relating to: desk identifiers, clearing arrangement indicator, new multi-leg modifiers, standardized reporting of yield or price and separate reporting of per-transaction ATS fees.
- FIF Back Office Committee. On January 19, Stephen Prosperi from the DTCC provided the Back Office Committee with an overview of DTCC’s Project Whitney, which relates to clearance and settlement for unlisted securities.
- Broker-Dealer Trading and Custody of Digital Asset Securities. On January 19, Lilya Tessler, a partner and head of Sidley’s NY FinTech and Blockchain group, discussed regulatory developments related to the emerging digital asset securities market. The discussion included a presentation on the recent SEC Statement on Custody of Digital Asset Securities by Special Purpose Broker-Dealers and the SEC Staff No-Action Relief Granted to FINRA for non-custodial Alternative Trading Systems.
- FIF Tax Information Reporting Working Group. On January 21, Wolters Kluwer conducted part one of a two-part series of spotlight presentations on virtual currencies. Wolters Kluwer tax and regulatory experts Stevie Conlon, Anna Vayser, Robert Schwaba, and Larry Perlman discussed the basics of virtual currencies and blockchain, and related regulatory issues. The discussion included an analysis of the impact of recent OCC Interpretive Letters and FinCEN guidance.
- Executive Orders 13959 and 13974. On January 22, FIF hosted a follow-up call on Executive Order 13959. On the call, representatives from DTCC reviewed recent Important Notices that they have issued relating to Executive Orders 13959 and 13974. Robert Dura and Satish Kini of the Debevoise law firm reviewed the new Executive Order 13974 issued on January 13 and the FAQs issued by OFAC on January 14.
Eduard Kotlyar