25 November, 2019
Working Group Updates 11/25/19
25 November, 2019
- FIF Reg ATS-N Working Group - FIF followed up with the group to gather additional feedback on the ATS's initial Reg ATS-N filing experiences. The feedback was incorporated into supplemental recommendations to FIF's prior comment letter on FIF Member ATS initial experience with filing Form ATS.
- FIF Front Office Committee - Please find this months' front office committee agenda here.
- FIF CAT Tech Spec Working Group - Reviewed FIF description of challenges and recommendations related to remaining Phase 2c CAT reporting challenges and ambiguities. Specifically, FIF focused on reject scenarios and business flows, the application of the Order Effective Timestamp, and additional challenges including the removal of “C” Reporting Exception Code in preparation for the Friday, November 22 in-person meeting with FINRA CAT.
- FIF Data & Technology Committee - The group featured a spotlight topic on the recent announcements regarding the Bakkt Exchange. FIF also covered our monthly Market Data Capacity Reports, summarized exchange and SIP technical notices and updates, and reviewed the recent and upcoming regulations that impact market data. Please find the complete Market Data Capacity Report here.
- FIF CAT Tech Spec Working Group - FIF walked-through the final draft of FIF’s Phase 2c CAT Reporting recommendations, eliciting final comments and suggested edits. FIF also focused on further industry recommendations, including additional use cases, business scenario examples, and additional Phase 2c challenges.
- FIF SEC Rule 606 Working Group - FIF focused on addressing interpretative issues related to the definition of “Venue” specific to Rule 606(a) reporting expectations. FIF further discussed the treatment of Floor Brokers and whether Floor Brokers are more appropriately considered Primary Routing Venues or Execution Venue/Secondary Routing Venue. FIF also addressed current implementation questions, including reporting IOIs, Fee/Rebates, and the identification of venues for the purpose of 606(b)(3) reporting. FIF will publish an updated version of the FIF Rule 606 Implementation Guide prior to the next Rule 606 Working Group Meeting.
- FIF CAT Committee - FIF Reviewed FINRA CAT responses to the Thursday, November 21 CAT Q&A meeting. FIF placed particular emphasis on the review of and obtaining member feedback on FINRA CAT’s proposed CAT Test Plan revision and the current status of the publication initial Phase 2e Tech Spec (LTID component). FIF concluded the Committee meeting with a final review materials presented to FINRA CAT/SROs on November 22 on Phase 2c specification/reporting challenges.
- FIF Cybersecurity Working Group - The group reviewed the NSA Technical Guidance on both Managing Risk from Transport Layer Security Inspection and Hardening Your SIEM Solution, as well as a high level introduction to the NSA/CSS Technical Cyber Threat Framework v2. FIF followed up with a discussion on what memebers wanted to see covered by the group going into the new year.
Eduard Kotlyar