03 September, 2019
Working Group Updates (Week of 9/3/19)
03 September, 2019
- FIF CAT Committee - FDID Focus - FIF held two working group meetings the week of 8/26 with the intent of gathering industry feedback questions, suggestions, and additional use cases pertaining to remaining gaps in FDID guidance. As part of these discussions, FIF sought to provide members an opportunity to ask and discuss common questions related to the implementation of FDIDs. FIF completed the feedback cycle and submitted our questions and recommendations to FINRA CAT on Thursday, August 29. FIF believes much of our feedback will be discussed on the September 10 industry outreach call on FDID.
- FIF Front Office Committee - FIF reviewed several notices, rule proposals, and updates focusing on potential impacts to front office trading technology. Chris Montagnino, Managing Director, Compliance Services, Jordan & Jordan concluded the Front Office Commitee meeting with a spotlight topic on the recently published SEC Rule 606 FAQs. Please find this month's agenda here.
- FIF SEC Rule 606 Working Group - FIF Reviewed in detail an industry proposal intended to allow all industry members the ability to provide introducing brokers downstream order routing and execution data as required pursuant to the recently published 606 FAQs. FIF will seek to achieve industry buy-in regarding the viablity of this proposal and socialize with the industry and regulators. FIF is further working with SEC Staff on a potential extension of the Rule's compliance date(s).
- FIF CAT Working Group - Connectivity Focus - FIF discussed with industry members the current status of CAT connectivity expectations and elicited feedback from members on additional detail that is required from FINRA CAT and the connectivity vendor in order to meet CAT Testing timelines. FIF has provided detailed feedback to FINRA CAT and will continue to advocate for additional information to be disseminated shortly.
- FIF TRACE Working Group - FIF completed review of Reg Notice 19-25 and elicited feedback and recommendations from industry members on FINRA's proposal to include U.S. Dollar Denominated Foreign Soverign Debt within the TRACE facility. FIF is in the process of completing a draft of a comment letter to FINRA presenting our questions and recommendations. FIF will hold a meeting shortly after the draft is finalized.
- FIF CAT Committee - FIF discussed the amended timing of the CAT/LTID industry proposal with members and engaged members with questions and provided clarity on timing implementation considerations. FIF also dicussed a recent letter submitted by the CAT Operating Committee to SEC Staff on their intent to formally request exemptive relief on broker-dealers' obligations to provide senstitive PII information to the CAT (i.e. SSN, actual DOB) in favor of a CCID solution. FIF also discussed updates on the current status of connectivity and provided an opportunity to review FINRA CAT's responses to industry member questions presented during the FINRA CAT sponsored Q&A session.
Eduard Kotlyar