On September 14, 2020, FIF submitted a comment letter to FINRA in response to FINRA Regulatory Notice 20-24. In the Regulatory Notice, FINRA requested comments on proposed changes to TRACE reporting, relating to delayed Treasury spot and portfolio trades. FIF would like to thank the FIF members who participated in the discussions relating to the rule proposal and provided the input that was incorporated in the comment letter. The FIF and other comment letters on this rule proposal are posted on the FINRA website here:  https://www.finra.org/rules-guidance/notices/20-24#comments.

Instead of sending Outlook invites on FINRA CAT's behalf for their checkpoint calls and webinars, FIF will post all FINRA CAT calls and webinars on the FIF Calendar located here: https://fif.com/index.php/calendar. Clicking on the FINRA CAT placeholder on the FIF calendar will reveal the specific FINRA CAT meeting URL where you will find the dial-in information, materials (usually uploaded right before the call) and option to save the meeting to your personal calendar. Another way to keep ontop of FINRA CAT meetings would be to simply bookmark and regularly check: https://catnmsplan.com/events

FINRA CAT is in the process of soliciting industry member feedback on behalf of its CCO in support of the Plan Processor’s annual review of the CAT clock synch and time increment reporting requirements. FIF has prepared a survey for members to complete. FIF requests that members please return completed responses to fifinfo@fif.com  by Friday September 18. All responses to FINRA CAT will be anonymized. If you did not receive the survey document from FIF, please email fifinfo@fif.com for a copy. 

On July 16, 2020, FINRA issued Regulatory Notice 20-24 requesting comments on proposed changes to TRACE reporting relating to delayed Treasury spot and portfolio trades. The comment period for the rule proposal expires today. On September 7th, FIF arranged a call with FINRA staff. During the call, FINRA staff provided background information on the rule proposal and responded to questions from FIF Members.  FIF will be submitting a comment letter on the rule proposal.

On September 3^rd, FINRA CAT issued a FAQ that Industry Members are not required to report an Order Modification Request or Order Cancel Request event to CAT in Phase 2d to the extent an order has already been fully executed or cancelled. However, reporting of this activity may be required in future phases of CAT. This is a positive result as FIF members were concerned about the system changes that would have been required for reporting these events to CAT.