29 June, 2020
Working Group Updates 6/29/2020
29 June, 2020
- FIF CSDR/EU Buy-In Working Group - FIF was joined again by Andy Hill, ICMA, and Matthew Johnson, DTCC, to continue the discussion on CSDR issues facing U.S.-domiciled broker-dealers. The European Union has requested ESMA to conduct a review of CSDR and FIF will be submitting a letter outlining these US-specific issues for ESMA to take into consideration.
- FIF SEC Rule 606 Working Group - FIF held two meetings this past week to discuss various remaining issues including 606(a) fees, specifically how to report the percentage of routed orders and whether options consolidators required to include 606(a) net payments/rebates received for orders sent on behalf of retail options brokers. The group also reviewed the scope of 606(b)(3) reporting data including fees/rebates, liquidity indicators, and the 606 Interchange method. FIF reviewed the current status of recent requests for additional clarity to SEC staff.
- CAT Options Working Group - FIF reviewed feedback from FINRA CAT on Paired Orders, including FINRA CAT's preferred Paired Order construct: reported as Single-Leg events with Paired Orders identified via a Paired Order ID and handling instructions. FIF continued with an overview of the current status of the Phase 2d Options spec development for Paired and Multi-Leg Orders to be published on June 30th and reviewed the Wednesday, June 17th Deep Dive on Paired Orders. The second weekly meeting reviewed the June 23rd Options Deep Dive with FINRA CAT, with the updates to the Multi-Leg and Paired Order reporting structures and the remaining issues to be discussed leading up to the draft specification publication.
- FIF Front Office Committee - Please find this month's Front Office agenda here.
- FIF Data & Technology Committee - The Committee meeting began with a spotlight presentation from SIAC focusing on the CTA SIP Migration to NYSE Pillar Technology. In addition to the presentation, FIF covered the normal monthly Market Data Capacity Reports, summarized exchange and SIP technical notices and updates, and reviewed recent or upcoming regulations that impact market data. Please find the Meeting Materials here and the full Market Data Capacity Report here.
- FIF Cybersecurity Working Group - This month's meeting started with a follow-up on Coronavirus-related scams and fighting cyberattacks with Game Theory. Additionally, FIF reviewed the most current CAT Cybersecurity Guidance with the CAT Production Environment now live. The group also discussed what the new normal will look like in the Cybersecurity space in response to current events.
- FIF CAT Tech Spec Working Group - The group discussd the recent the CAT Repository System Outage of SFTP functionality resulting in file rejections across the industry. This sparked the discussion on the expectations of the CAT Reporter during these instances and the need for better communication from FINRA CAT of these issues when they arise. FIF also covered the additional Phase 2c spec published with the handling instructions and event, order effective time (MEOE). The group also discussed the CAT Erroneous Events Self-Reporting Form which is intended to identify have firms self-identify errors that firms know to be errors from the assessment of their own data that were not identified at the repository level.
- FIF CAT Committee - FIF continued discussion on the CAT Erroneous Events Self-Reporting Form and the CAT Systems Outage [SFTP] implications and expectations on CAT Reporters going forward during these instances. FIF also reviewed the revised CAT IM Phase 2a/2b and Phase 2c Tech Specs, with a focus on the new handling instruction and event for Order Effective Time.
Eduard Kotlyar