April 16, 2024 - FIF Back Office Committee Agenda
Meeting Details
- When: Tuesday April 16, 2024 11am et
Meeting Agenda
- DTCC Updates
- FICC Updates
- April 2, 2024: GOV1675-24 - Certificate of Incumbency – Member Updates Required
- March 22, 2024: 34-99844 - Notice of Filing of Proposed Rule Change to Modify the GSD Rules (i) Regarding the Separate Calculation, Collection and Holding of Margin for Proprietary Transactions and That for Indirect Participant Transactions, and (ii) to Address the Conditions of Note H to Rule 15c3-3a
- March 21, 2024: 34-99817 - Notice of Filing of Proposed Rule Change, as Modified by Partial Amendment No. 1, to Modify the GSD Rules to Facilitate Access to Clearance and Settlement Services of All Eligible Secondary Market Transactions in U.S. Treasury Securities
- DTC Updates
- April 5, 2024: 34-99911 - Notice of Filing and Immediate Effectiveness of Proposed Rule Change to Update the Deposits Service Guide and the Operational Arrangements
- April 4, 2024: DDR55 - Revised DDR Rulebook
- April 3, 2024: 19927-24 - MyDTCC Portal Client Inquiry Requests
- March 27, 2024: 19913-24 - DTC’s Federal Reserve Deliver Order/Fedwire Securities Transfer Message Change
- March 27, 2024: 19914-24 - Reminder: New Requirement for Announcement and Payment Detail Submission to DTC
- March 22, 2024: 19893-24 - DTC Proposed Rule Change – Updates to the Deposits Service Guide and the Operational Arrangements (SR-DTC-2024-004)
- March 22, 2024: 34-99843 - Notice of Filing and Immediate Effectiveness of Proposed Rule Change to Amend the DTC Corporate Actions Distributions Service Guide and the DTC Settlement Service Guide
- March 15, 2024: 19866-24 - Enhancements to the MyDTCC Inquiry Support Portal for Securities Processing Inquiries
- NSCC Updates
- April 1, 2024: A9415 - ACATS - NEW ACCOUNT TYPE CODES (for SECURE ACT 2.0)
- FICC Updates
- OCC
- April 5, 2024: T+1 Equity Settlement Cycle Conversion * * *REMINDER* * *
- April 3, 2024: Reminder: DDS Change - Stock Loan Trade Capture Message
- April 3, 2024: Increase to Minimum Clearing Fund Cash Requirement
- March 28, 2024: MIAX Sapphire Options Exchange Updated Dates
- SEC
- March 19, 2024: Share Repurchase Disclosure Modernization
- CAT Updates
- April 10, 2024: 34-99938 - Notice of Filing of Amendment to the National Market System Plan Governing the Consolidated Audit Trail Regarding Cost Savings Measures
- TMPG
- February 28, 2024: Meeting Minutes
- FINRA Updates
- TRACE
- April 8, 2024: FINRA FIX VPN Clients
- March 21, 2024: TRACE Corporate/Agency Re-Platform and Data Feed Protocol Changes
- Additional FINRA Updates
- March 22, 2024: Trade Reporting Notice - Advance Notice: Upcoming Trade Reporting Enhancements for Fractional Share Transactions
- March 19, 2024: Regulatory Notice 24-08 - FINRA Adopts Amendments Relating to Protected Option and Warrant Positions Under FINRA Rule 4210
- TRACE
- FIF Member Questions
- If you would like to submit anonymized questions for the group to discuss, email us at fifinfo@fif.com and we will include it on the next agenda.
- FIF Working Group Updates: Please click here to Join Working Groups
- CAT Transaction Reporting
- Recent Developments
- FINRA CAT has published notification that the compliance date for reporting the new handling instructions for auctions will be moved to July 1
- FINRA CAT has hosted a webinar and provided additional FAQs and other guidance on the handling instructions for auctions
- On March 28 FINRA CAT published updated Technical Specifications for CAT, including additional guidance for reporting auction-related handling instructions and for reporting RFQ responses that are not immediately actionable
- On April 12 FINRA CAT published updates to the Reporting Scenarios document
- FIF areas of focus
- On February 29 FIF submitted a letter to the SEC requesting clarification on CAT reporting for various representative order scenarios
- On March 21 FIF submitted an exemptive request letter to the SEC relating to linkage of representative orders to customer orders and linkage of order fulfillments to representative and principal orders
- At the request of FINRA CAT, a group of FIF members will be participating in a meeting with SEC, CAT Plan Participant and FINRA CAT representatives on May 14 to discuss the representative order scenarios presented by FIF in its February 29 letter
- On March 21, 2024 FIF submitted an exemptive request letter to the SEC on port settings; the exemptive request letter incorporates by reference the points made by FIF in a January 25 letter to the SEC
- On February 26 FIF submitted a letter to the CAT Plan Participants and FINRA CAT requesting confirmation that firms can report to CAT order modifications that do not change the material terms of an order
- The CAT Plan Participants have requested that FIF submit a proposed FAQ to address this issue; the FIF Working Group is working on this proposed FAQ
- The Working Group is discussing a draft FIF letter to the SEC requesting extension of the deadlines (i) for the CAT system to communicate errors to CAT reporters, and (ii) for industry members to correct CAT errors
- The Working Group is discussing a draft FIF letter to the SEC relating to RFQ responses that are not immediately actionable
- Recent Developments
- CAT Billing
- Recent Developments
- On January 2 and 3 FINRA and the other SROs submitted rule filings with the SEC relating to the collection of CAT fees from industry members
- On January 17 the SEC published notices for each of these rulings
- On February 13 the notices were published in the Federal Register
- FIF Areas of Focus
- On March 4 FIF submitted a comment letter to the SEC focused on CAT billing and reconciliation
- Recent Developments
- CAT CAIS
- Recent developments
- FINRA CAT updated the CAT production system on February 26, including a historical data reload, a new Outstanding Rejections feedback file, the re-enabling of inconsistency checks, new feedback files for Material Inconsistencies, new inconsistency codes to distinguish between intra-firm and inter-firm inconsistencies, and expansion of the correctionAction of DELETE to cover all data validation errors
- On February 29 FINRA CAT published updates to the CAIS Reporting Scenarios
- On March 8 FINRA CAT published updates to the CAIS Technical Specifications
- FIF areas of focus
- The CAIS Working Group continues to review the recent updates to the CAIS Reporting Scenarios and CAIS Technical Specifications and plans to submit comments and questions to FINRA CAT
- The CAIS Working Group continues to discuss the February 26 CAIS updates and issues in preparation for the Full CAIS live date
- Recent developments
- Rule 605
- The SEC adopted amendments to Rule 605 on March 6
- FIF continues to host calls to review and discuss the Rule 605 amendments
- FIF has scheduled the next Rule 605 Working Group call for Tuesday April 16
- FINRA Rules 6151 (centralized reporting of Rule 606(a) reports) and 6470 OTC Routing Reports
- On February 26 FINRA published Regulatory Notice 24-05, which provides guidance on the implementation of Rules 6151 and 6470
- FIF hosted calls on March 11 and 14 to discuss implementation of Rules 6151 and 6470
- On March 15 FIF submitted a letter to FINRA on the implementation of Rules 6151 and 6470
- On March 18 FINRA hosted a call for FIF members to discuss implementation of Rule 6151
- TRACE and MSRB RTRS
- On February 15 FIF submitted a comment letter on the rule filings by FINRA and the MSRB to reduce -- from 15 minutes to one minute – the timeframe for reporting corporate, agency and muni bonds to TRACE and the MSRB RTRS system
- FIF submitted a supplemental comment letter on February 26
- Securities Lending Transparency
- During May 2024 FINRA is scheduled to publish Technical Specifications and other documentation relating to implementation of the new securities lending transparency system
- FIF will schedule Working Group calls to review the FINRA documentation after publication by FINRA in May
- Short Positions and Activity Reporting
- FIF has hosted calls for the FIF Short Sales / Reg SHO / Short Interest Reporting Working Group to review and discuss implementation of the SEC’s recent adoption of a rule to require monthly reporting of short positions and short activity
- Dealer Registration
- On February 22 Ignacio Sandoval of the Morgan Lewis law firm reviewed the rule recently adopted by the SEC to expand the definition of a “dealer”
- Section 31 Fee Collection Process
- On November 2 FIF submitted a letter to FINRA requesting that FINRA provide additional data to industry members to facilitate reconciliation of Section 31-related fees
- On December 18 FIF members participated on a call with FINRA representatives to discuss this presentation
- FIF has contacted FINRA to schedule a follow-up discussion
- Fractional Shares on the TRF
- On March 22 FINRA published a Trade Reporting Notice for an upcoming change to allow for reporting of fractional share transactions to the TRF and ORF
- In connection with the FINRA Trade Reporting Notie, the SIAC and UTP plans published updated technical specifications to provide for dissemination of fractional share trades
- These changes will take effect no earlier than the first quarter of 2025
- FIF has hosted a Working Group call to review the FINRA notice and the updated SIAC and UTP documentation
- FIF has scheduled the next Working Group call for Thursday April 18
- Tax Information Reporting Working Group
- The Tax Information Reporting Working Group will meet on Thursday where Wolters Kluwer will present on amendments to the Section 871(m) regulations applying the Section 871(m) withholding tax on “dividend equivalent payments” to long U.S. equity-linked derivative positions that have a “delta” of .8 or greater
- Cybersecurity Working Group
-
Matt Weinberg of CISA presented on 1/31 on the Current Threats to the Financial Industry. The group also covered some notable releases from FINRA, and the NSA. The next quarterly update will be in May.
-
- Data & Technology Committee
- FIF Industry Solutions Offering
- FIF Retail Execution Quality Statistics
- FIF Regulatory Initiatives Tracking Site - (Requires FIF Website Login)
- FIF Monthly Reports
- Market Data Capacity Statistics – (Requires FIF Website Login)
-
Next Meeting Date: May 21, 2024 @ 11am ET
__________________
Financial Information Forum
fifinfo@fif.com
FIF URL: www.fif.com
- CAT Transaction Reporting
FIF has a policy of strict compliance with federal, state, and international antitrust laws. This policy applies to all meetings and events conducted by FIF and all meetings attended by representatives of FIF. FIF members should avoid discussing certain subjects when they are together – both at formal FIF events and membership, committee, and other meetings as well as during informal contacts with other industry members.
Under no circumstances should the meetings be used as a means for competing companies or firms to reach any understanding – expressed or implied – that restricts competition or in any way impairs the ability of meeting participants to exercise independent business judgment regarding matters affecting competition. It is the responsibility of all meeting participants to be aware of antitrust regulations and to prevent any written or verbal discussions that violate, or appear to violate, these laws.
