Short Position Reporting. FIF hosted two calls this past week on short position reporting. During the first call, FIF members updated the Working Group on a call with SEC Commissioner Peirce relating to the implementation of short position reporting. The Working Group also discussed the inability to submit XML tables through the EDGAR web portal, technical challenges with submitting test files to EDGAR, reporting for a position that is short vs. the box, reporting for securities that do not have a CUSIP or other identifier, and which version of FIGI to report. During the second call, the...

TRACE / RTRS. The Working Group discussed a rule change by the Federal Reserve Board relating to the reporting by Covered Depository Institutions (CDIs) of Treasury trades to TRACE. The Working Group reviewed the updated list of CDIs posted by FINRA. The Working Group discussed the need to split the current combined settlement and reporting process for munis into separate processes. The Working Group discussed questions from FIF members relating to one-minute reporting and the requirement to report a manual trade indicator. Rule 606; FINRA Rule 6470. The Working Group discussed Rule...

Short Position Reporting. FIF members provided an update to the Working Group on a December 9 call with the SEC staff on the Technical Specification and EDGAR filing issues. The Working Group discussed whether firms are reporting FIGIs at the Global Share Class or Country Composite level. The Working Group discussed EDGAR filing issues.  OFR Repo Reporting Working Group. The OFR Repo Reporting Working Group discussed reporting for cancels. The Working Group discussed a scenario where a repo is executed in the evening and the trade timestamp is after the file observation date,...

Short Position Reporting; Reg SHO. The FIF Short Sales / Reg SHO / Short Reporting Working Group continued its discussion of the implementation of short position reporting. FIF members provided an update to the Working Group on a December 2 call with representatives from the SEC’s Division of Trading and Markets and Division of Economic and Risk Analysis relating to the calculation of Form SHO reportable amounts. The Working Group discussed a Form SHO reporting scenario where an account changes from negative to positive. The Working Group discussed the most recent updates to the Form SHO...

Short Position Reporting. The FIF Short Sales / Reg SHO / Short Reporting Working Group continued its discussion of the implementation of short position reporting. FIF members provided an update to the Working Group on a November 22 call with representatives from the SEC’s Division of Trading and Markets and Division of Economic and Risk Analysis relating to the calculation of Form SHO reportable amounts. The Working Group discussed reporting requirements relating to LEIs, CUSIPs and FIGIs, calculating whether a firm meets Threshold A for a security, and how settlement dates should be...

Short Position Reporting. The FIF Short Sales / Reg SHO / Short Reporting Working Group continued its discussion of the implementation of short position reporting. FIF members provided an update to the Working Group on a November 15 call with SEC representatives relating to the calculation of Form SHO reportable amounts. The Working Group discussed next steps on this issue, including the submission by FIF of updated reporting scenarios. FIF submitted these updated scenarios to the SEC. On November 22 FIF members participated on a follow-up call with representatives from the SEC’s Division...

Back Office Committee. The Back Office Committee reviewed applicable FICC, DTC, NSCC, SEC, MSRB, OCC, IRS and FINRA updates during the past month. The spotlight presenter was Sheila Zak of the Options Clearing Corporation, who provided an update on external testing for OCC Ovation. Please find this month's agenda here. CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group discussed whether to include CAT fees in EBS reporting, the auction handling instructions, reporting for order and route modifications and linkage for OTC Link order fulfillments. The...

Short Position Reporting. FIF hosted two calls this past week for the Short Sales / Reg SHO / Short Reporting Working Group to continue the discussion of the implementation of short position reporting. The Working Group reviewed and made final edits to a supplemental letter to the SEC. FIF submitted this letter to the SEC. The Working Group reviewed a draft request to the SEC for an extension of the compliance date for Form SHO reporting. FIF submitted this extension request to the SEC. The Working Group discussed a summary of the October 24 FIF member call with the SEC. The Working Group...

Short Position Reporting. FIF hosted three calls this past week for the Short Sales / Reg SHO / Short Reporting Working Group to continue the discussion of the implementation of short position reporting. During the first call, Working Group members provided an update on a call with the SEC staff on October 24. The Working Group continued its discussion of current implementation challenges, including reporting for convertible bonds. During the second call, the Working Group discussed engagement of vendors, the product scope for short position reporting, reporting the issuer LEI, and...