During October 2018, FIF Members presented recommendations to the SEC staff for the modernization of Rule 605. These recommendations, which were developed through the FIF Rule 605 Working Group, were focused on updating Rule 605 to reflect market changes since the adoption of Rule 605 in 2000.  At the request of FIF Members, on February 25 FIF held a meeting for the FIF Rule 605 Working Group to discuss reviewing and updating these recommendations. The Working Group reviewed the proposals from October 2018 and agreed to proceed with updating the recommendations to present to the SEC during 2021. The next Working Group meeting is scheduled for Thursday March 18 at 11 am (ET). If you are not a member of the Rule 605 Working Group and would like to join, update your working group subscriptions in your profile here: https://fif.com/index.php/profile. If you're having trouble, or forgot your password, email fifinfo@fif.com for assistance.

On March 2, the FIF TRACE Working Group will meet to review a draft comment letter on a rule proposal by the Federal Reserve to expand TRACE reporting to certain depository institutions that are not broker-dealers. The comment letter is focused on the potential impact for broker-dealers that currently report to TRACE.

On February 25, FIF Members participated on a call with FINRA CAT and the Plan Participants to discuss CAIS reporting for authorized traders. Also, on February 25, the FIF CAT Co-Chairs participated on a call with FINRA CAT to discuss proposed Phase 2d changes relating to partial cancels, net price orders and the opening and closing of IDQS quotes.

A FIF Member has requested feedback from other FIF Members on the question below. If you have any information on this question, please send an email to fifinfo@fif.com.

Are member firms currently going through, or have gone through, the application process with ASIC regarding a foreign Australian Financial Services (AFS) License? The member firm is currently going through the application process and has a question regarding board member background checks. The member firm uses a background check vendor. The background information from that vendor was provided; however, they are being told that only original source documentation is acceptable, and that ASIC will not accept vendor documentation. Have other FIF members gone through this process and if so what type of background documentation did they provide? Did firms have to get documentation from the various regulatory and government entities separately (FINRA, SEC, FBI, etc.)? 

This series involves multiple panels for FIF Members addressing the implementation considerations of the 898 page Rule. The panels are moderated by Tom Jordan, FIF Advisory Chair. The kickoff panel on February 1st focused on the Rule Overview and featured Wayne Aaron of the Vedder Price law firm and Matt Billings of Two Sigma. The second webinar, taking place on February 8th, focused on core data and consolidated market data. This webinar featured John Ramsay of IEX, Rich Steiner of RBC and Rob Mohan of Wellington.

The next panel, scheduled for today at 4pm ET, will focus on Governance & Pricing.  The panel will include James Angel from the Georgetown McDonough School of Business, Tom Etheridge of Jordan & Jordan, and Colin Clark of MEMX. After registering, you will be prompted to follow a link to Zoom, in order to add the Webinar to your calendar. If your firm is a non-member or blocks Zoom, please email the Program Office at fifinfo@fif.com for dial-in details. FIF Members may register here.