On November 23, 2021, FINRA filed SR-FINRA-2021-029 with the SEC, “Proposed Rule Change to Amend FINRA Rule 6732 (Exemption from Trade Reporting Obligation for Certain Transactions on an Alternative Trading System)”. On December 1, 2021, FINRA filed SR-FINRA-2021-030 with the SEC, “Notice of Filing of Proposed Rule Change to Amend FINRA Rule 6730 to Require Members to Append Modifiers to Delayed Treasury Spot and Portfolio Trades When Reporting to TRACE.” FIF has scheduled the next call for the TRACE Working Group for Tuesday December 14 at 2pm ET to continue the Working Group discussion of these filings and to review a draft comment letter.  

On December 7, 2021, FIF submitted to FINRA additional requests from FIF members for interpretive guidance relating to the Supplemental Liquidity Schedule (SLS) recently adopted by FINRA (see FINRA Regulatory Notice 21-31). The SLS takes effect on March 1, 2022. If you are interested in participating in discussions with other FIF members on this topic, please send a note to fifinfo@fif.com.

Last week FIF held it's annual Year-End CAT Webinar. FIF Advisory Chair, Tom Jordan, moderated a strong panel where we took a look back to the retirement of OATS, important accomplishments in CAT for 2021 and we looked ahead to the major CAT initiatives of 2022 and beyond. Panelists included Shelly Bohlin of FINRA CAT, Jon Kroeper of FINRA, Will Leahey of Refinitiv and Mitvin Shah of Societe Generale. If you are a FIF Member and you missed the webinar, you may request a recording at fifinfo@fif.com. 

FIF has scheduled the Annual FIF CAT Webinar for Thursday December 9 at 4pm ET. The panel participants are Shelly Bohlin of FINRA CAT, Jon Kroeper of FINRA, Will Leahey of Refinitiv, and Mitvin Shah of Société Générale. Tom Jordan of Jordan & Jordan will act as the moderator in this discussion. To attend this webinar, please register here. If you have any questions, please email us at fifinfo@fif.com. 

On December 2, 2021, FIF submitted a comment letter in response to FINRA Regulatory Notice 21-35, “FINRA Requests Comment on Proposed Order Routing Disclosure Requirements for OTC Equity Securities and Potential Steps to Facilitate Investor Access to Current Order Routing Disclosures for NMS Securities”.