11 January, 2021
Working Group Update 1/11/2021
11 January, 2021
- FIF Spotlight on Executive Order 13959. On January 6, FIF hosted a call on the recent Executive Order 13959, which prohibits certain transactions in publicly traded securities of any Chinese military company or any securities that are derivative of, or are designed to provide investment exposure to, such securities. During the call, Robert Dura and Satish Kini of the Debevoise & Plimpton law firm reviewed recent FAQs issued by OFAC relating to the Executive Order.
- FIF CAT Committee and Tech Specs Working Group. The CAT Tech Specs Working Group reviewed updated FINRA CAT FAQs relating to the initiatorFlag, trades priced at a Net Asset Value, the CSC handlingInstruction, reporting of RFQs for the equity leg of a complex order, and the exemption for Options Market Maker quotes. The Working Group reviewed the FINRA CAT request for feedback on firm practices for accepting and rejecting orders. The Working Group reviewed draft questions and comments to FINRA CAT relating to route modifications and cancels, reporting scenarios relating to internal routes, the YE flag, the ALG handlingInstruction, the solicitationFlag, and orders received the evening prior to a symbol change. FIF submitted these comments and questions to FINRA CA. The CAT Committee reviewed the 2021 timeline. The Committee discussed the FINRA CAT request for feedback on firm practices for accepting and rejecting orders. The Committee discussed the FINRA CAT proposal relating to CAIS Customer and Account Types. The Committee reviewed updated planned Industry Member Technical Specification updates.
- FIF CAT CAIS Working Group. The CAT CAIS Working Group discussed various material inconsistency scenarios based on firms submitting delta files or full daily refreshes. The Working Group discussed requesting functionality that would enable firms to send daily submission of all CAIS records. The Working Group reviewed a notification from the SEC’s Office of Compliance, Inspections and Examinations relating to compliance with the large trader rule. The Working Group discussed the FINRA CAT proposal relating to CAIS Customer and Account Types.
Eduard Kotlyar