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Discussions > Regulations > SEC 13h-1 rule

SEC 13h-1 rule

Complete message thread from old site

FIX Trading Community
973 days ago,(2011/08/24)

[ original email was from John Greenan - john.greenan@alignment-systems.com ]
Hi All,

Does anyone have any views on the implementation of SEC rule 13h-1 (the larger trader rule) within FIX? Specifically how will the LTID be transmitted from buy-side to sell side - tag 1, tag 58, custom tag or out-of-band?

http://www.sec.gov/rules/final/2011/34-64976.pdf

I have raised this today with a number of large US brokers and I'd like to see if there is an industry wide consensus rather than trying to reinvent the wheel.

Since this is about regulation I am aware that some folks are not able to post publicly in discussion forums and suchlike. Please feel free to contact me offline and I will happily anonymise and repost here.

Thanks.

FIX Trading Community
972 days ago,(2011/08/25)

[ original email was from John Harris - john.harris@bondmart.com ]
John,

I do not see how we can solve this problem on our own. In fact, we shouldn't even try. After all, the promulgation of this new dicate by Dear Leader Shapiro was made necessary solely on account of our collective stupidity, incompetence, and dishonesty. How can we be trusted to figure out a proper protocol for its implementation? What if we do the job poorly or, even more likely given our criminal natures, advance a design that will make our next crop of market manipulation schemes even more profitable - or even help Emmanuel Goldstein fund his hateful enterprise?

No, clearly, if we are not fit to trade with one another without government surveillance, we are not fit to design technology for compliance with government requirements. I would respectfully suggest that you direct your question to our superiors at the SEC. Perhaps they can take a break from their document shredding long enough to tell us what FIX messages and fields we should use so that they can rule us better.

Your fellow goodthinker,
John

> Hi All,
>
> Does anyone have any views on the implementation of SEC rule 13h-1 (the larger trader rule) within FIX? Specifically how will the LTID be transmitted from buy-side to sell side - tag 1, tag 58, custom tag or out-of-band?
>
> http://www.sec.gov/rules/final/2011/34-64976.pdf
>
> I have raised this today with a number of large US brokers and I'd like to see if there is an industry wide consensus rather than trying to reinvent the wheel.
>
> Since this is about regulation I am aware that some folks are not able to post publicly in discussion forums and suchlike. Please feel free to contact me offline and I will happily anonymise and repost here.
>
> Thanks.

Manisha Kimmel
972 days ago,(2011/08/25)

We do not anticipate needing a FIX tag at this point since this detail is likely to be captured with account information rather than on an order by order basis. If the industry does determine a FIX tag is required then the FIF/FPL Regulatory Reporting Working Group will work to create a gap analysis.

Manisha Kimmel
Executive Director
Financial Information Forum

> Hi All,
>
> Does anyone have any views on the implementation of SEC rule 13h-1 (the larger trader rule) within FIX? Specifically how will the LTID be transmitted from buy-side to sell side - tag 1, tag 58, custom tag or out-of-band?
>
> http://www.sec.gov/rules/final/2011/34-64976.pdf
>
> I have raised this today with a number of large US brokers and I'd like to see if there is an industry wide consensus rather than trying to reinvent the wheel.
>
> Since this is about regulation I am aware that some folks are not able to post publicly in discussion forums and suchlike. Please feel free to contact me offline and I will happily anonymise and repost here.
>
> Thanks.