FIF Rule 605 Working Group. The Rule 605 Working Group discussed the SEC’s recent rule proposal on Disclosure of Order Execution Information. FIF TRACE/Fixed Income Working Group (MSRB RTRS reporting). On January 10, FIF and FIF members participated on a call with MSRB representatives to discuss the comment letter that FIF submitted in response to MSRB Notice 2022-07 (“Request for Comment on Transaction Reporting Obligations under MSRB Rule G-14”). During the call with MSRB representatives, FIF members discussed the importance of providing executing firms the ability to report directly...

FIF Rule 606 Working Group. The Rule 606 Working Group discussed next steps relating to FINRA’s rule filing with the SEC on OTC routing disclosures. The Working Group discussed reporting of OTC Link routing scenarios under the FINRA rule filing. FIF is currently working on a draft supplemental comment letter on proposed reporting for trading activity involving the OTC Link ATS. FIF TRACE/Fixed Income Working Group. At the request of MSRB staff, on December 20, 2022 FIF and FIF members participated on a call with MSRB representatives to discuss the comment letter that FIF submitted in...

FIF Rule 606 Working Group. The Rule 606 Working Group continued its review and discussion of a draft FIF comment letter on the rule filing submitted by FINRA to the SEC on Disclosure of Order Routing Information for OTC Equities (SR-FINRA-2022-031). FIF submitted this comment letter on December 20.   FIF CAT CAIS Working Group. On December 20, 2022 FIF members participated on a call with SEC staff to discuss the prior request submitted by FIF members for an extension of the Full CAIS compliance date. The Working Group discussed this call and next steps. The Working Group...

FIF TRACE/Fixed Income Working Group. The TRACE/Fixed Income Working Group discussed FINRA Regulatory Notice 22-26 (“Trade Reporting and Compliance Engine (TRACE): FINRA Requests Comment on Proposed Changes to TRACE Reporting Relating to Delayed Treasury Spot Trades”), FINRA Regulatory Notice 22-27 (“TRACE Reporting of U.S. Treasury Securities: FINRA Adopts Enhancements to TRACE Reporting for U.S. Treasury Securities”), and FINRA Regulatory Notice 22-28 (“TRACE Reporting of Foreign Sovereign Debt Securities: FINRA Adopts Amendments to Require Reporting of Transactions in U.S....

FIF Rule 606 Working Group. The Rule 606 Working Group discussed the rule filing submitted by FINRA to the SEC on Disclosure of Order Routing Information for OTC Equities (SR-FINRA-2022-031). The Working Group continued its prior discussion of the recent Risk Alert published by the SEC’s Division of Examinations on Observations Related to Regulation NMS Rule 606 Disclosures. Fractional Share Orders. FIF hosted a joint call for the Compliance and Surveillance Working Group andthe Back Office and Front Office Committees focused on fractional share orders. Topics of discussion included...

FIF Data and Technology Committee. The Data and Technology Committee reviewed capacity, latency and volume data for the prior month for the equity, options, currency, crypto and futures markets. The spotlight presenter was Brent Yates of IEX, who discussed IEX cloudSwXtch. Please find the meeting materials here and the full capacity statistics deck here.  CAT Monthly Update Working Group Call. The Working Group reviewed guidance and updates from the CAT Plan Participants and FINRA CAT on CAT transaction reporting and CAT CAIS reporting during the prior month. The Working Group...

FIF Rule 606 Working Group. The Rule 606 Working Group discussed the recent Risk Alert published by the SEC’s Division of Examinations on Observations Related to Regulation NMS Rule 606 Disclosures. FIF CAT CAIS Working Group. FIF submitted a letter to FINRA CAT requesting that certain open issues relating to inaccurate CAIS error feedback be escalated to a priority of High.

Fractional Share Orders. FIF hosted a joint call for the Compliance and Surveillance Working Group and the Back Office Committee focused on fractional share orders. Topics of discussion included: fractional share workflows; routing of orders and allocation of executed shares; trading capacity (mixed agency versus principal); restrictions on trading as principal for affiliated advisory accounts; classification of fractional share orders as held and not held; orders received prior to market open; trading along (FINRA Rule 5320); and TRF and CAT reporting issues. Cybersecurity Working...

CAT Monthly Update Working Group Call.  The CAT Monthly Update Working Group reviewed guidance and updates from the CAT Plan Participants and FINRA CAT on CAT transaction reporting and CAT CAIS reporting during the prior month. The Working Group also reviewed the current areas of focus for FIF members and the current open issues for CAT transaction reporting and CAT CAIS reporting. FIF CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed a recent FIF call with the CAT Operating Committee in which representatives of the CAT Operating...