13 July, 2020
Working Group Updates 7/13/2020
13 July, 2020
- FIF CSDR/EU Buy-In Working Group - FIF submitted a letter to ESMA requesting guidance in support of our members' continued efforts in meeting CSDR's mandatory buy-in provision on February 21, 2021. FIF raised several issues related to cross-jurisdictional settlement.
- FIF CAT Committee - FIF began an initial review of the Phase 2d Technical Specification, with a focus on the Equities-only updates, including the new Phase 2d Requirement mandating a new OrderID be assigned when an order is modified and cancel/replaced. FIF also reviewed the issue and anticipated resolution of orders originated before June 22 go-live and the application and implementation of CAT Handing Instructions.
- FIF CAT Tech Spec Wokring Group - FIF provided a summary discussions with FINRA CAT on the requirement for a new Order ID on Order Modification/Cancel Replace events in Phase 2d. This topic will be addressed Tuesday, July 14 at 9:00am in a meeting with FINRA CAT. FIF also covered which orders originated prior to go-live and how industry members are still getting error code 3501 rather than a warning. FIF also discussed overall CAT enforcement and regulatory jurisdiction as well as FIF's intended comments on the proposed amendments to FINRA Rule 6800. Industry members believe that instead of finding the rules applicable to each SROs, this is merely a copy and paste issue.
- FIF SEC Rule 606 Working Group - In preparation for an upcoming meeting with SEC T&M Staff, FIF reviewed recent discussion topics including 606(a) fee/rebate designation discrepancy, Round Lot designation, and 606 Fee Inclusiveness (i.e. execution fees v. other fees). The group also discussed 606(b)(3) readiness including data availability, interpretative issues, and IOIs.
Eduard Kotlyar