Working Group Update 11/9/2020

FIF CAT Tech Specs Working Group and FIF CAT Committee. The FIF CAT Working Group reviewed the issues discussed during the November 3 FINRA CAT Weekly Industry Testing Checkpoint call, including various exchange linkage error scenarios and guidelines for firms on when to open and update cases with FINRA CAT. The Working Group discussed various issues raised by FIF members, including obtaining guidance on reporting for Manning rule compliance where a firm trades as principal, inconsistent OATS and CAT exchange lists, various exchange linkage error scenarios, challenges with the OSCI symbol not being provided on named errors for options, and the need for intra-day symbol updates. FIF submitted various member questions and comments to FINRA CAT.

FIF CAT CAIS Working Group. The FIF CAIS Working Group completed and submitted responses to FINRA CAT relating to data submission, the error correction process and account transfers. The Working Group submitted various questions and issues to FINRA CAT relating to ULTIDs, LTID reporting for certain institutional trading scenarios, and other issues. The Working Group continued its review of, and responses to, the questions from FINRA CAT relating to account and customer types and inconsistency management.

FIF Rule 606 Working Group. The Working Group discussed the responses from the SEC staff relating to the PDF renderer, the reporting of not held IOC orders, and the Rule 606(b)(3) reporting for executions that involve more than two levels of routing. The Working Group discussed the focus of the regulators on verifying that firms are consistently reporting across different reporting requirements, including OATS, CAT and Rule 606. The Working Group discussed reporting for various floor broker scenarios and various GTC order scenarios.