Exam Alert: FINRA Revises OATS, ORF, and ADF/TRF Trade Reporting Rules

FINRA is revising the trade reporting rules for the Order Audit Trail System (OATS) and for FINRA facilities. The changes require… Continue reading

FINRA is revising the trade reporting rules for the Order Audit Trail System (OATS) and for FINRA facilities. The changes require:

  • reporting additional times for certain transactions
  • expressing trade times in milliseconds
  • linking reversal reports to the original trade
  • reporting trades on non-business days and trades that are over a year old to FINRA facilities
  • using a new “step-in” indicator (when a firm takes over a position from another firm)
  • keeping declined trades in the system so they may still be cancelled, corrected, or accepted

Effective April 7, 2014, FINRA has modified the rules for the Order Audit Trail System (OATS).

Effective September 15, 2014, FINRA will modify the rules for the OTC Reporting Facility (ORF).

Effective September 29, 2014, FINRA will require firms to report the time of trades in milliseconds when reporting to the Alternative Display Facility (ADF) or to Trade Reporting Facilities (TRFs).

FINRA will implement the other changes to ADF and TRF reporting rules in the first quarter of 2015.

Source: FINRA Regulatory Notice 14-21: SEC Approves Amendments to Equity Trade Reporting and OATS Rules

This alert applies to the Series 7, Series 24, Series 55, and Series 62.

Exam Alert: FINRA requires firms to report trades within 10 seconds

Effective November 4, 2013, FINRA will require firms to report OTC trades in equity securities within 10 seconds of execution. Firms must also report cancellations of trades within 10 seconds. Continue reading

Effective November 4, 2013, FINRA will require firms to report OTC trades in equity securities within 10 seconds of execution. Firms must also report cancellations of trades within 10 seconds.

Note that trades should be reported “as soon as practicable.” 10 seconds is the cut-off after which the trade report will be considered late. FINRA recognizes, however, that certain trade reports may need to be entered manually – in these situations, FINRA will consider the complexity and size of the trade in determining whether there is “reasonable justification” for manually entering the trade report.

Source: Regulatory Notice 13-19: SEC Approves Amendments to Require Firms to Report OTC Transactions in Equity Securities as Soon as Practicable, But No Later Than 10 Seconds, Following Execution

This alert applies to the Series 24, Series 55, and Series 62.

Exam Alert: FINRA reinstitutes short sale exempt marking on trade reports

Effective February 28, 2011, FINRA has reinstituted the “short sale exempt” marking for trade reporting in over-the-counter transactions. In addition, Continue reading

Effective February 28, 2011, FINRA has reinstituted the “short sale exempt” marking for trade reporting in over-the-counter transactions.  In addition, Order Audit Trail System (OATS) route reports must include, if applicable, price and a short exempt identifier.  “Short sale exempt” indicators are used for short sales of stocks that may be marked “short exempt” under Regulation SHO. Relevant to the Series 7, Series 62 and Series 24 exams.

http://www.finra.org/Industry/Regulation/Notices/2010/P122255

The types of sales that qualify as short exempt may be found under Rules 201(c) and 201(d) of Regulation SHO: http://taft.law.uc.edu/CCL/regSHO/rule201.html#c.