July 30, 2024 - FIF Front Office Committee Agenda

Meeting Details

When: July 30, 2024 @ 11am ET

Meeting Agenda

Spotlight Presentation: Mark Davies, S3, FINRA Rules 6151, 6470 and SEC Rule 605 Update

FINRA Updates:
- TRACE
  - July 18, 2024: Notice of Designation of Longer Period for Commission Action on Proceedings to Determine Whether to Approve or Disapprove a Proposed Rule Change to Amend FINRA Rule 6730 (Transaction Reporting) to Reduce the 15-Minute TRACE Reporting Timeframe to One Minute
  - July 18, 2024: FINRA Response to Comments on FINRA Rule 6730 (Transaction Reporting) to reduce the 15-minute outer-limit TRACE reporting timeframe to one minuteFINRA Rule 6730 (Transaction Reporting) to reduce the 15-minute outer-limit TRACE reporting timeframe to one minute
- Additional FINRA Updates
  - July 12, 2024: Information Notice - 7/12/24 - FINRA Reminds Registered Persons and Firms of Continuing Education Requirements
  - July 9, 2024: Notice of Filing and Immediate Effectiveness - Proposed Rule Change to Amend FINRA Rule 8312 (FINRA BrokerCheck Disclosure)
  - July 1, 2024: Information Notice - 7/1/24 - Members of the U.S. Subgroup of the Intermarket Surveillance Group (ISG) Highlight Role of the Cross-Market Regulation Working Group (CMRWG)
  - June 27, 2024: Regulatory Notice 24-09 - FINRA Reminds Members of Regulatory Obligations When Using Generative Artificial Intelligence and Large Language Models
CAT Updates:
- July 25, 2024: Q19. When will full account refreshes be required?
- July 24, 2024: CAT Industry Member Technical Specifications (2d) v4.1.0 r3 (Clean)
- July 23, 2024: CAT Alert 2024-01: Mapping of Exempted Port-Level Settings
- July 19, 2024: 2024 Industry Member Releases (Transaction) - Scope and Schedule
- July 19, 2024: FDID Refresh Report Metadata Feedback File Schema
- July 19, 2024: FDID Refresh Report Data Feedback File Schema
- July 10, 2024: Full CAIS Industry Member Release Rollout
- July 8, 2024: CAT LLC Response to Comments - Historical CAT Assessment 1 (6/13/2024)
SEC:
NMS
- July 18, 2024: 34-100556 - Joint Industry Plan; Notice of Designation of a Longer Period for Commission Action on the Twenty-Third Amendment to the National Market System Plan to Address Extraordinary Market Volatility
- July 15, 2024: 34-100530 - Order Instituting Proceedings to Determine Whether to Approve or Disapprove an Amendment to the National Market System Plan Governing the Consolidated Audit Trail Regarding Cost Savings Measures
- July 11, 2024: 34-100500 - Notice of Designation of a Longer Period for Commission Action on a Proposed National Market System Plan Regarding Consolidated Equity Market Data
- July 11, 2024: 34-100495 - Notice of Designation of a Longer Period for Commission Action on a Proposed Amendment To Modify Section 5.2(c)(iii) of the OPRA Plan Relating to Dissemination of Exchange Proprietary Data Information
Exchange Updates:
- NYSE
  - July 19, 2024: 34-100565 (Arca) - Notice of Designation of a Longer Period for Commission Action on Proceedings to Determine Whether to Approve or Disapprove a Proposed Rule Change to Amend Exchange Rule 5.3-O to Permit the Listing and Trading of Options on Commodity-Based Trust Shares
- NASDAQ
  - July 3, 2024: 34-100461 - Notice of Filing of Proposed Rule Change to Modify the Application of Bid Price Compliance Periods
  - June 27, 2024: 34-100445 - Notice of Filing and Immediate Effectiveness of Proposed Rule Change to Launch Proximity-On-Demand, a Managed Colocation Solution
- Cboe
  - July 23, 2024: 34-100582 (BZX) - Notice of Filing and Immediate Effectiveness of a Proposed Rule Change to Establish New Logical Ports in Connection with a New Connectivity Offering on its Equity Options Platform
  - July 12, 2024: 34-100524 - Notice of Filing and Immediate Effectiveness of a Proposed Rule Change to Reduce the Length of Time Between the End of its Current Global Trading Hours Session and the Beginning of its Regular Trading Hours
- MIAX
  - July 19, 2024: SR SAPPHIRE 2024 01A Proposal to establish the MIAX Sapphire Top of Market (“ToM”) data feed, MIAX Sapphire Complex Top of Market (“cToM”) data feed, and MIAX Sapphire Liquidity Feed (“SLF”)
  - July 15, 2024: In the Matter of the Application of MIAX Sapphire, LLC for Registration as a National Securities Exchange; Findings, Opinion, and Order of the Commission (SEC Notice)
- Green Impact Exchange
  - July 17, 2024: Green Impact Exchange, LLC; Notice of Filing of Application for Registration as a National Securities Exchange Under Section 6 of the Securities Exchange Act of 1934
FIF Member Question:
- 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
  - On May 20 the SEC issued an exemptive order extending from July 31, 2024 to July 31, 2026 the exemption for reporting NIA RFQ responses to CAT
  - The requirement to report the new handling instructions for auctions went live on July 1
- FIF areas of focus
  - On March 21 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 May 7 FIF submitted a comment letter in support of the CAT NMS plan amendment filed by the CAT Plan Participants to reduce CAT operating costs
  - On May 14 FIF members participated in a meeting with SEC, CAT Plan Participant and FINRA CAT representatives on linkage of representative orders to customer orders and linkage of order fulfillments to representative and principal orders
  - On July 2 FIF submitted an updated 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
  - On July 19 FIF submitted comments and questions to FINRA CAT relating to the recent changes to the auction-related handling instructions
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
  - The FIF Working Group continues to discuss CAT billing and reconciliation processes and challenges
CAT CAIS
- Recent developments
  - Full CAIS went live on May 31, 2024
- FIF areas of focus
  - With Full CAIS now live, the FIF Working Group is focused on proposing enhancements to the CAIS reporting system, including enhancements previously submitted by FIF to FINRA CAT
  - During July, FIF members participated on calls with FINRA CAT representatives to discuss these proposed enhancements to CAIS
EBS Retirement
- During June, FIF members participated on a call with SEC representatives to discuss EBS retirement
Rule 605
- On June 24 FIF submitted a letter to the SEC relating to implementation of the SEC’s amendments to Rule 605
FINRA Rules 6151 (centralized reporting of Rule 606(a) reports) and 6470 (OTC routing reports)
- FINRA Rule 6151 became effective on June 30; firms must submit their Rule 606(a) reports to FINRA by July 31
- FIF members are awaiting further guidance from FINRA on FINRA Rule 6470
TRACE and MSRB RTRS
- On April 22 the SEC published Orders Instituting Proceedings in response to 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
- On May 17 FIF submitted a comment letter in response to the SEC’s Orders Instituting Proceedings
- The SEC is required to approve or disapprove the MSRB rule filing by January 23 and is required to approve or disapprove the FINRA rule filing by January 24
SLATE Reporting Systems for Securities Loans
- On May 1 FINRA submitted a rule filing with FINRA to establish the new SLATE (Securities Lending and Transparency Engine) reporting system for securities loans
- During May FINRA published a draft Participant Specification for SLATE
- The SLATE Working Group is working on a comment letter on the FINRA rule filing and the draft Participant Specification
Short Positions and Short Activity Reporting
- On June 24 FIF submitted a letter to the SEC relating to implementation of the SEC’s new Form SHO reporting requirements
- On July 15 FIF members participated on a call with SEC representatives to discuss the questions and issues raised in the FIF letter
- The FIF Working Group is working on a follow-up letter to the SEC

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
- On May 16 FIF submitted a letter to FINRA with comments and questions relating to the implementation of this new reporting requirement
CFTC Large Trader Reporting
- On April 30 the CFTC adopted changes to its large trader reporting requirements
- FIF hosted calls to discuss the CFTC’s recent amendments to this reporting requirement
- FIF will submit a letter to the CFTC with comments and questions relating to these changes
OFR Repo Reporting
- On May 6 the Treasury Department’s Office of Financial Research adopted a new requirement for firms that exceed specified thresholds to report repos that are executed bilaterally and not centrally-cleared (NCCBR repos)
- On June 20 FIF submitted a letter to the OFR with issues and questions relating to implementation of the new reporting requirement
- On July 17 FIF submitted a supplement letter to the OFR with additional issues and questions relating to implementation of the new reporting requirement
Compliance and Surveillance
- On July 30 FIF will host a webinar on trade surveillance
- Holly Dito of Pershing will moderate the panel; the panelists will be Steve Bonanno of BXS, Ted Karn of The Karn Group, Chris Montagnino of Jordan & Jordan, and Jeremy Vest of S3
- FIF has invited the members of the Compliance and Surveillance Working Group for the panel
Tax Information Reporting Working Group
- The next meeting will be on August 1st where the focus will be on the Final IRS Digital Asset Broker Reporting Regulations
Emerging Technologies Working Group
- The next meeting will be on August 8th where the focus will be on IT and storage challenges of financial services companies
Cybersecurity Working Group
- Matt Weinberg of CISA presented on May 23 on the Current Threats to the Financial Industry. The group also covered some notable releases from FINRA and the NSA.
Data & Technology Committee
- Please find last month's Meeting Materials deck here and Capacity Statistics deck here.
- FIF will hold our next call on July 31 at 10am ET where the spotlight presentation will focus on the MIAX Sapphire Launch.
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: August 27, 2024 @ 11am ET

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FIF URL: www.fif.com

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