FIF SEC Equity Market Proposals Working Group (Reg NMS). The Working Group discussed a revised draft of the FIF comment letter on the SEC rule proposal on Regulation NMS: Minimum Pricing Increments, Access Fees and Transparency of Better Priced Orders, including the potential increase in message traffic resulting from the proposed MPI changes, implementation process and timing, market resiliency issues, and the recommendation for a phased implementation of the proposed MPI changes.  FIF Rule 605 Working Group. The Rule 605 Working Group discussed a revised draft of the FIF comment...

FIF TRACE/Fixed Income Working Group. The TRACE Working Group discussed recent TRACE FAQ updates by FINRA relating to reporting the portfolio trade modifier and TRACE reporting for foreign sovereign bonds. The Working Group discussed questions from FIF members relating to TRACE reporting for Reg S transactions and currency conversion for TRACE reporting. FIF Rule 605 Working Group. The Rule 605 Working Group discussed a revised draft of the FIF comment letter on the SEC’s rule proposal on Disclosure of Order Execution Information, including reporting the number of shares that could have...

FIF Rule 605 Working Group. The Rule 605 Working Group discussed the first draft of a comment letter on the SEC’s rule proposal on Disclosure of Order Execution Information, including on the following topics: reporting time to execution for marketable orders that exceed the size of the protected quotation; reporting the number of shares that could have been filled; reporting average percentage price improvement and average percentage spread; and the proposed summary report. FIF SEC Equity Market Proposals Working Group (Order Competition Rule). The Working Group discussed the first draft...

FIF Rule 605 Working Group. The Rule 605 Working Group continued its discussion of the SEC’s recent rule proposal on Disclosure of Order Execution Information, with a focus on how each item in the summary report should be calculated, weighted-average E/Q and the implementation time period. FIF SEC Equity Market Proposals Working Group (Order Competition Rule). The Working Group continued its discussion of the SEC’s recent rule proposal on Disclosure of Order Execution Information, including potential conflicts with FINRA Rule 5310.01 (execution of marketable customer orders), FINRA Rule...

OFR Proposal on Reporting for Bilateral Repos. The OFR Repo Reporting Working Group and the TRACE/Fixed Income Working Group continued the review and discussion of a draft FIF comment letter on a recent proposal by the Treasury Department’s Office of Financial Research to require daily reporting for non-centrally cleared bilateral repos. FIF Rule 605 Working Group. The Rule 605 Working Group continued its discussion of the SEC’s recent rule proposal on Disclosure of Order Execution Information, with a focus on reporting E/Q for the summary execution report, reporting for segmented...

SEC Order Competition Rule Proposal. Members of the Data and Technology Committee, the Front Office Committee and the Compliance and Surveillance Working Group continued their discussion of the SEC’s Order Competition Rule proposal, including auction priority rules, the need to ensure sufficient auction capacity before auctions are introduced in production, unsuccessful auctions, attribution of the originating broker, and requirements for the originating broker to maintain anonymity. FIF Rule 605 Working Group. The Rule 605 Working Group continued its discussion of the SEC’s recent...

SEC Order Competition Rule Proposal. Members of the Data and Technology Committee, the Front Office Committee and the Compliance and Surveillance Working Group continued their discussion of the SEC’s Order Competition Rule proposal, including the exception for certain large orders, impact on best execution obligations, auction responses, surveillance of auction activity, attribution of the originating broker, the exception from the attribution requirement, failed auctions and submitting market orders as segmented orders. FIF Rule 605 Working Group. The Rule 605 Working Group...

Regulation Best Execution. James Dombach and Larry Bergmann of the Davis Wright Tremaine law firm  presented to members of the Front Office Committee and the Compliance and Surveillance Working Group on the SEC’s recent Regulation Best Execution rule proposal. FIF Front Office Committee. The Front Office Committee reviewed applicable updates and notices from the SEC, FINRA, FINRA CAT and the equity and option exchanges. The spotlight presenters were Ari Burstein and Sharon Flanagan of IntelligentCross, who discussed the recent FINRA filing with the SEC to add IntelligentCross as a...

FIF Rule 605 Working Group. The Rule 605 Working Group continued its discussion of the SEC’s recent rule proposal on Disclosure of Order Execution Information, including order type categories, reporting based on notional value, reporting for orders received after the open and prior to the primary listing market disseminating its first firm quotations for the applicable security, reporting for mid-peg orders, reporting for segregated orders, providing an exemption for an introducing firm that routes all orders to its clearing firm, reporting for IOC and stop orders, removing the...