18 November, 2019
Working Group Updates 11/18/19
18 November, 2019
- FIF CAT Committee - FIF reviewed the next steps following the initial Phase 2c CAT Industry Member Tech Spec (V3.0), which featured only minimal changes, and the concerns over the 2c feedback schedule. The group discussed concerns with the multifactor authentication requirement for the CAT Reporter Portal and the proposed resolution to IMID. Finally, FIF reviewed the status of their current CAT subgroups (OTC Equities, Options, Tech Spec Review) and the next steps for each group.
- FIF Reg ATS-N Working Group - FIF discussed the existing challenges discussed on a recent call with the SEC regarding EDGAR filing. FIF is in the process of writing an informal letter to the SEC with the industry feedback/recommendations.
- FIF Back Office Committee - Please find this months' back office committee agenda here.
- FIF/SIFMA/STA Multi-Leg Options Subgroup - The subgroup discussed multi-leg options modeling scenarios, specifically how to report non-CAT reportable legs in a multi-leg order and which format of data would be the most useful for regulators.
- FIF Reg Best Interest Working Group - FIF discussed leveraging existing definitions for scoping out the differences between retail and institutional customers for systems integration, specifically needing to clarify the expectation of whether family offices meeting the intended definition of retail. The group also discussed the need for guidance around Form CRS delivery and informed consent.
- FIF SEC Rule 606 Working Group -The group reviewed execution broker-dealer data delivery methods, focusing on if introducing brokers believe they have access to all the required 606 data and whether executing brokers are providing all the necessary data. The group also discussed how fee & rebate information is provided back from exchanges today and what format would work best at passing back the most accurate information. Finally, the group discussed the ambiguous definition of "venues" as defined in 606(a).
- FIF CAT Tech Spec Working Group - FIF lead the discussion around anticipated advocacy with respect to CAT Phase 2c Techincation Specifications, specifically focusing on cancel scenarios. FIF requests for firm's input on anticipated development time and costs relating to systems builds for reporting cancellation scenarios to help industry argument to defer cancellations to a later CAT Phase. The second meeting focused around the challenges with Order Effective Timestamp (OET) and ambiguity around the handling instructions that trigger OET. The group also had a discussion on Phase 2c Rep orders and rep order linkages.
- FIF Retail Execution Quality Working Group - FIF discussed rebranding the working group to possibly Execution Quality Transparency and discussed the Rule 605 modernization recommendations previously offered by members including additional topics ot be included (i.e. premarket open orders, stop-loss orders).
Eduard Kotlyar