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The SEC staff have advised FIF that the SEC is considering the expansion of Rule 605 to cover options. The SEC staff have requested input from FIF on this topic. The FIF Rule 605 Working Group is working on a set of recommendations relating to Rule 605 for options. The next meeting for this Working Group is scheduled for Tuesday October 12 at 2pm ET.

On September 30, members of the FIF Rule 606 Working Group met with the staff of the SEC’s Division of Trading and Markets to discuss the challenges with Rule 606 look-though for options. The next meeting of the FIF Rule 606 Working Group is scheduled for Thursday October 14 at 10am ET. During this meeting, Working Group members will review a draft request for exemptive relief relating to options look-through to be submitted by FIF to the SEC. Working Group members also will discuss Rule 606 reporting for multi-leg orders and FINRA’s recent Regulatory Notice 21-35, which proposes to extend Rule 606 reporting to OTC equities.

Because of the large number of issues that the CAIS Working Group is currently reviewing, FIF has scheduled an additional CAIS call for Monday October 11 at 11am ET. This call will focus on the continuing review of the most recent updates to the Full CAIS Reporting Scenarios. This call is in addition to the standing Wednesday and Friday CAIS Working Group calls.

On September 29, 2021, FIF submitted a comment letter on FINRA Regulatory Notice 21-19, “FINRA Requests Comment on Short Interest Position Reporting Enhancements and Other Changes Related to Short Sale Reporting”. FIF would like to thank the members of the FIF Short Sales/Reg SHO/Short Interest Reporting Working Group for their participation and input in the drafting of the comment letter.