FIF News
FIF CAT Phase 2a and Phase 2b Readiness Survey
Industry Members are currently planning for Phase 2a and Phase 2b roll-out and therefore require sufficient notice to appropriately plan for Phase 2a and Phase 2a go-lives (unfreeze technology, revise coding, etc..). FIF has developed a short survey designed to assess firms' current readiness should follow-up with the Regulators be required. Please find a link to the survey here. If your firm blocks access to the Survey Monkey site, please let us know and we will send you a Word version of the survey. Please note that all responses will be kept confidential.
FIF Reminds Member Firms of COVID-19 Resources
As a reminder, the Regulators continue to offer guidance specific to COVID-19 related challenges. Specifically, FIF would like to highlight two important notices published by the SEC last week. On Thursday, Chairman Clayton published a statement specifying that Reg Best Interest compliance dates will not be extended beyond June 30. In that notice, Chair Clayton emphasized that compliance with Reg BI as well as other current rule obligations will be assessed case-by-case under a ‘best efforts’ standard. FIF believes this statement provides the industry with assertion that the facts and circumstances in play at each firm will be taken account in the Commission’s assessment of firms’ compliance with upcoming and current rule requirements. Please also note that the SEC Division of Trading and Markets issued a statement specifying standards with respect to certain paper submissions until June 30. Please find additional information related to paper filing requirements here and note FIF is currently working with the SEC with respect to Form ATS and Form ATS-R filings. Finally, please refer to the SEC COVID-19 landing page here and FINRA’s COVID-19 landing page here for additional notices and guidance.
SEC Grants FIF and STA Request for an Extension of Certain 606(a) and 606(b)(3) Compliance Dates
On March 25, 2020, the SEC granted FIF and STA’s request for temporary exemptive relief of certain 606(a) and 606(b)(3) requirements in response to the continued proliferation of disruption in operations following the outbreak of COVID-19. In summary, the SEC has extended the following near-term Rule 606 deliverables: 1) 30-day extension Rule 606(a) - Broker-dealers are exempt from the requirement to provide the public report covering the first quarter of 2020 required by Rule 606(a) until May 29, 2020 and 2) 60-day extension Rule 606(b)(3) - Broker-dealers that engage in outsourced routing activity (second route/look through) are exempt from the requirement to collect the monthly customer-specific data required by Rule 606(b)(3) for such activity until June 1, 2020, and are not required to provide customers with reports covering in-scope data until July 29, 2020. Please click here to read the Extension Order.
FIF to Reconvene Regularly Scheduled CAT Working Group Meetings
FIF intends to begin hosting more frequent CAT Working Group Members beginning with the week of March 30, starting with the FIF/STA/SIFMA CAT Phase 2d Options Subgroup on Tuesday, March 31 at 2:00pm and the CAT Tech Spec Requirements Working Group on April 1 at 2:00pm et. FIF will disseminate notes following each meeting.
SEC and FINRA Continue to Update COVID-19 Guidance
As a reminder, the SEC and FINRA continue to update resources intended to provide industry members with guidance, best practices, rule filings, and notices related to COVID-19. FIF encourages members to review both the SEC’s COVID-19 Resource Page and FINRA’s COVID-19 Resource Page frequently as additional resources are added daily.
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