11 November, 2019
Working Group Updates 11/11/19
11 November, 2019
- FIF CAT Committee - FIF reviewed FINRA CAT's responses to the Industry Member Q&A session, focusing on the details around third-party extranet providers for CAT reporting, the proposed IMID construct, and the full IMID Conflict List. FIF reviewed the initial Phase 2c CAT Industry Member Tech Spec (V3.0) which featured only minimal changes. The group discussed the key dates of the Phase 2c tech spec review schedule, with the final review period ending on January 14, 2020. Industry members also discussed concern over the CAT Reporter Portal's App verification the CAT Reporting Agent's personal device.
- FIF SEC Rule 606 Working Group - FIF and Industry Members discussed the collective need for re-formatting of exchange invoices in order to better parse out fee and rebate information for 606(b)(3) reporting, including suggestions for a machine-readible format to be sent by exchanges alongside the invoices. FIF also covered the transmission of data for the look-through component and the treatment of floor brokers in relation to 606 reporting.
- FIF Retail Execution Quality Working Group - The group addressed gaps in 605 reporting from when it was codified to reviewed FIF's previous 605 Modernization Recommendations and elicited industry member feedback on additional recommendations. Additional recommendations discussed included stop-loss orders and a separate category for customer type.
- FIF CAT Tech Spec Working Group - FIF reviewed initial feedback on too late to cancel/rejected customer cancel request scenarios for Phase 2c reporting. FIF also gathered feedback on anticipated industry development costs and challenges in reporting these cancel events. Industry members also discussed a request for exemptive relief of WORM compliance under CAT. FIF also plans to raise in a formal letter a conformist period after the finalization of the 2c spec in January.
Eduard Kotlyar