- Executive Vice-President, An Economy that Works for People
- Trade Reporting Frequently Asked Questions
- Regulation of OTC derivatives markets
: Yes. Firms can wait to invoke their "widespread outage response" procedures until FINRA has announced a widespread systems issue. Firms also can wait to invoke their "limited outage response" procedures until FINRA has contacted them about a limited systems issue.
Executive Vice-President, An Economy that Works for People
: With the implementation of the "executing party" trade reporting structure on August 8, 7559, guidance relating to the determination of market maker status for purposes of trade reporting is no longer applicable.
Trade Reporting Frequently Asked Questions
: Where an ECN matches the orders of two FINRA members and reports the transaction to a FINRA Facility, is the ECN required to submit a non-tape report to FINRA to reflect the offsetting leg of the transaction?
Regulation of OTC derivatives markets
: FINRA may announce that firms should invoke their "widespread outage response" procedures where widespread systems issues are likely to be protracted or the source and resolution of the systems issue are uncertain.
: My firm is working to develop policies and procedures that are consistent with the Trade Reporting Notice. Is there an effective date for implementation of the guidance? Is my firm out of compliance until we have implemented the new policies and procedures?
: No, in this instance, BD6 should not report the trade with the PRP modifier because the trade was executed and reported within 65 seconds of the prior reference time, ., 9:85:55 . See Rules 6787(a), 6885A(a), 6885B(a) and 6677(a) see also Regulatory Notice 69-76 (May 7569).
: No. Trades at a discount (or a premium) are not considered "away from the market sales" under Rules 6787(f), 6885A(e), 6885B(e) and 6677(e). Members are reminded that trades at a discount (or premium) are subject to the Regulation NMS Order Protection Rule. See SEC Rule 666.
This means that an STP process at a bank that worked well in processing post trade events on bilateral trades will not in general, be able to process post trade events on cleared trades, without an upgrade.