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General Q/A
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Re: Covered short-sell cash equity order
FPL Program Office / FIX Protocol Ltd. <>
24 Sep 2008 9:33AM ETFor your information, this is the document that FPL published which details the high-level mapping of changes that were made to FIX in order to comply with Regulation SHO: http://www.fixprotocol.org/documents/1004/FPL%20Americas%20REG%20SHO%20(2).pdf.
> One more update after looking at this further -
>
> There were some discussions regarding the concept of affirmative
> determination. Generally, "affirmative determination" means that your
> client affirms the ability to borrow securities in good deliverable
> form within three business days. I brought this up a long time ago, see
> also here:
>
> http://www.fixprotocol.org/discuss/read/87f2eaa5
>
> Having said that, Instinet, at some point, had an option to send 54=7 to
> denote a short sell without affirmative determination, which sounds like
> a naked short to me. Therefore, 54=5 would imply the short is covered.
> This is of course a matter of agreement, and 54=7 is not actually
> intended for this purpose either.
>
> --ws
>
> > Tom,
> >
> > I cannot speak for the actual spirit of the recent short selling ban;
> > I don't know if simply submitting 54=5 and 114 (not 113 by the way)
> > would satisfy the regulation.
> >
> > Ideally, when shorting (let's leave the naked scenario out for now)
> > and having an agreement with a broker or two in place I would send:
> >
> > 54 = 5 114 = N 5700 = [broker who located]
> >
> > This is a common implementation of Reg SHO.
> >
> > If you get 114=Y, 5700 should not be required as you are now asked
> > (required?) to provide the merchandise.
> >
> > Tag 203 is indeed meant for Options, but maybe it could be
> > "repurposed" in your environment?
> >
> > I have seen a few cases where the customer simply states "covered
> > short sell" in the text field.
> >
> > --ws
> >
> >
> >
> >
> > > In the current environment where regulators of equities markets are
> > > imposing constraints on short selling (naked and/or covered), we are
> > > looking at mechanisms within FIX that allow buy-side clients to
> > > specify that their equity order is covered by a lending agreement.
> > >
> > > One option we see is:
> > > - Using Tag 54 (side) = 5 sell short
> > > - Using Tag 113 (LocateReqd) = Y/N
> > >
> > > Where 54=5 and 113=Y, this would imply that the short sell is
> > > covered (at least if the receiving broker can locate the stock).
> > >
> > > Where 54=5 and 113=N, this doesn't disambiguate naked short selling
> > > from the case of covered short selling where the receiving broker
> > > does not need to provide stock borrow (i.e. seller has other lending
> > > agreement in place).
> > >
> > > Is there another option? Tag 203 (CoveredOrUncovered) doesn't appear
> > > applicable to cash equities.
> > >
> > > --
> > > Tom
Re: Covered short-sell cash equity order
FPL Program Office / FIX Protocol Ltd. 24 Sep 2008 9:33AM ET
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