On November 2, FIF submitted a presentation to FINRA that discusses (i) the current challenges faced by industry members in reconciling the FINRA Regulatory Transaction Fee (charged by FINRA to recoup Section 31 fees) and (ii) a proposal from FIF members to address this challenge. The FIF member proposal involves FINRA providing additional data to industry members to enable reconciliation of these fees. FIF has requested a call with FINRA to discuss the FIF member proposal. FIF would like to thank the participants in the FIF Section 31 sub-group for their participation in the drafting of this proposal.

FIF has scheduled the next call for the FIF Securities Lending Transparency Working Group for Monday November 6 at 2 pm ET. Ignacio Sandoval of the Morgan Lewis law firm will complete the review of the SEC’s recently-adopted rule to require Reporting of Securities Loans. The Working Group will also discuss various implementation issues relating to the rule proposal raised by FIF members, including how end-of-day should be defined, how a platform or venue should be defined, timestamp granularity, how spread-based pricing should be reported to FINRA and disseminated by FINRA, and reporting on an “if-known” basis. If you would like to participate on this call and are not a member of the Securities Lending Transparency Working Group, please update your FIF profile or send a note to fifinfo@fif.com.

FIF has scheduled the next call for the FIF Rule 606 Working Group for Monday November 6 at 3:30 pm ET to continue the discussion of Rule 606 reporting for the pass-through of CAT fees. The Working Group will also discuss issues and questions from FIF members relating to Rule 606 reporting.

FINRA CAT will host a second CAT Billing Webinar on Tuesday November 7 at 4:15 pm ET. FIF has sent a calendar invite for this webinar to the members of the FIF CAT Transaction Reporting Working Group.

FIF has scheduled a call for Thursday November 9 at 2 pm ET to continue the review of regulatory reporting fines for 2022 and 2023. The Working Group will also review a summary of findings for each regulatory report, including CAT, EBS, LOPR, Rule 605, Rule 606, short interest reporting, swap data reporting, TRACE, trade advertising and TRF/ORF. All firm names and dates are excluded from the presentation. FIF has invited the members of the Compliance and Surveillance Working Group and the newly-created Regulatory Reporting Fines Working Group to participate on this call. If you would like to participate on this call and are not a member of either Working Group, please update your FIF profile or send a note to fifinfo@fif.com. A number of members have asked FIF to distribute the digest document from the prior call to the Working Group members. FIF is currently making additional edits to this document and will distribute the document with the agenda that FIF sends out on Thursday morning.