FINRA Rule 6151 – Centralization of SEC Rule 606(a) Reports
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FINRA Rule 6151 (Disclosure of Order Routing Information for NMS Securities) requires members to submit to FINRA for centralized publication the order routing reports required under the Securities and Exchange Commission’s (SEC) Rule 606(a) (Rule 606(a) Reports). FINRA will centralize access to all Rule 606(a) Reports on its website to make these reports more accessible for regulators, investors, and others seeking to:
- Better understand how firms route and handle orders.
- Assess the quality of firms’ order handling services.
- Understand whether a firm is effectively managing potential conflicts of interest that may impact its routing decisions.
Purpose of the Requirement
The purpose of Rule 6151 is to provide investors and the public with centralized access to the reports currently required by SEC Rule 606(a), which include detailed information about the order routing practices of member firms and any payment for order flow arrangements. By centralizing access to Rule 606(a) Reports, FINRA will facilitate access to information used by investors to help them make informed decisions, aligning with FINRA’s commitment to promoting fairness, efficiency, and investor protection in the financial markets.
| Phase Description | Milestone | Expected Timeline |
|---|---|---|
| Firm Entitlement Setup (Registration and test account creation form) | Registration & Testing | Starts 5/13/24 |
| Industry Testing (Guidance) | Testing | 6/5/24 - 7/31/24 |
| Go Live | Production | 7/1/24 |
| 606 Report Submission (Q2, 2024) | Production | 7/1/24 - 7/31/24 |
Starting July, 1 2024, firms will be able to up upload their Rule 606(a) Reports electronically, using either manual file upload through the FINRA Gateway or through a direct machine-to-machine interface using fileX.
FINRA Rule 6151 Order Routing Information Filing Guide version 2
FINRA Gateway Submission
Go to https://gateway.finra.org and use your existing FINRA user ID and password to login. Upon logging in, submit your firm’s Rule 606(a) Report filing by clicking the upload icon on the left navigation bar.
The Super Account Administrator (SAA) at each firm has the ability to assign user access rights to the Rule 606(a) Report submission for the SAA and other firm employees. If your firm has designated an SAA for FINRA systems, contact that individual to change your existing user account or to create a new user account, as necessary. To determine whether your organization has an SAA, log in to the FINRA Gateway, click on “My Account” and view information from the “Applications & Administrators” link.
If your firm has not yet named an SAA, your firm must do so to submit Rule 606(a) Reports. Instructions regarding how to authorize someone at your firm to serve in this role are available in the Filing & Reporting section of FINRA’s website.
If you are not yet familiar with the FINRA Gateway, a brief tutorial is available from the login screen. If you have any difficulties with your FINRA login, please contact your firm’s Account Administrator for assistance.
FileX Submission
For a machine-to-machine file transfer, please see the documentation for fileX. You will need to contact the FINRA Support Group to establish access for submitting the Rule 606(a) Reports.
Firms may submit corrections to their Rule 606(a) Reports by submitting a replacement file using the same steps used to submit the initial filing.
The following resources were designed to help support FINRA members navigate the intricacies of Rule 606 reporting. Explore the materials below to empower your understanding and implementation of reporting requirements. If you have any questions or need further assistance, the support team is just a click away.
FINRA Related Resources
SEC
- SEC’s 2018 Amendments to Rule 606 of Regulation NMS
- SEC’s Order Routing and Handling Data Technical Specification
- SEC’s Division of Trading and Markets, Responses to Frequently Asked Questions Concerning Rule 606 of Regulation NMS
- SEC’s Division of Market Regulation, Staff Legal Bulletin No. 13A: Frequently Asked Questions About Rule 11Ac1-6
Onboarding Guides & Other Guidance
- FINRA Rule 6151 Order Routing Information Filing Guide v2 - Latest (Onboarding Guide)
- FINRA Rule 6151 Order Routing Information Filing Guide v1 (Onboarding Guide)
- 606 Testing Guidance
Support and Assistance
For technical questions or entitlement issues, please contact the FINRA Support Center at (800) 321-6273.
FINRA Rule 6151 Frequently Asked Questions
The following FAQ address general FINRA Rule 6151 questions. For detailed information please refer to the Onboaring guides.
Entitlements
1. What specific entitlements should firms ask for to submit Rule 606(a) Reports?
Firms should request the “SEC Rule 606 NMS Reporting” entitlement to submit Rule 606(a) reports to FINRA.
2. Are different entitlements required for uploading via machine-to-machine (M2M) and FINRA Gateway?
No. The Same entitlements can be used to upload documents via M2M (fileX) or FINRA Gateway.
3. Will firms be required to obtain different entitlements for the submission of Order Routing Information for OTC Equity Securities?
Yes, firms will be required to request different entitlements for submission of Order Routing Information for OTC Equity Securities.
4. Can a firm switch the method of report submission at anytime?
Yes, either method can be used at anytime.
Introducing Member Firms Adopting Clearing Firm Rule 606(a) Reports by Reference
1. When does an introducing member firm have to disclose its clearing firm relationship(s) to comply with Rule 6151?
Where, pursuant to existing SEC guidance, a member introducing firm intends to comply with Rule 606(a) order routing disclosure requirements by adopting its clearing firm’s Rule 606(a) Report by reference, the member introducing firm must discloses its clearing firm relationship(s) as described in the FINRA Rule 6151 Order Routing Information Filing Guide.
2. If there have been no changes to an introducing member firm’s clearing firm relationship(s) during a given quarter, does an introducing member firms have to re-submit clearing firm relationship information every quarter?
No. Once an introducing member firm submits to FINRA a list of its clearing firm(s) and the hyperlink to the webpage where the introducing firm discloses its clearing firm relationship(s) and adopts the clearing firm’s reports by reference, such introducing member firm is only required to update FINRA if the information previously provided changes.
3. How should an introducing firm provide an update regarding a clearing firm relationship change?
The introducing firm must submit a new “clearing firm relationship” file. For additional information on how to submit a clearing firm relationship File please see the FINRA Rule 6151 Order Routing Information Filing Guide.
4. How will the clearing firm relationship information be displayed on finra.org?
1. To provide access to all Rule 606(a) Reports in one location, reports submitted by clearing firms referenced in clearing relationships will be listed on finra.org under both the clearing firm and the introducing firm.
2. The clearing firm reports associated with the introducing firm will be identified based on the quarter prior to the clearing relationship information being submitted. For example, if the clearing firm relationship information is submitted on 07/10/2024, the clearing firm submissions for Q2 2024 (and going forward) will also be listed under the introducing firm. If the clearing relationship is changed, any clearing firm reports that were already submitted for the prior quarter will be adjusted to reflect the change in relationship. For example, if the clearing firm relationship information is updated on 01/31/2025, any clearing firm reports for Q4 2024 that are no longer used for the introducing firm would be disassociated from the introducing firm and any clearing firm reports for Q4 2024 that are now included in the relationship information would appear under the introducing firm. These updates would be reflected the day after the information has been submitted.
Multiple Rule 606(a) Report Submissions
1. Can a firm submit multiple Rule 606(a) Reports for a calendar quarter? If so, how should the firm submit these reports?
Yes, a firm can submit multiple Rule 606(a) Reports for a calendar quarter. When submitting multiple reports, firms must include a label (‘Context') in the file name to differentiate between multiple reports (e.g., a firm may use an MPID or other identifier as the context label to indicate different reports. See the FINRA Rule 6151 Order Routing Information Filing Guide for more information.
2. How can firms that submit multiple Rule 606(a) Reports submit corrections?
The same ('Context') label used to differentiate reports must be used in the file name to submit a correction. See the FINRA Rule 6151 Order Routing Information Filing Guide for more information.
Other 606 FAQ's
1. Can firms include links in the Rule 606(a) Reports submitted to FINRA?
Yes, firms can include explanatory links in the “Material Aspects” section of Rule 606(a) reports where for example a firm provides context for the firm’s reports (e.g., an explanation of why a firm is producing multiple reports). This will not affect file validations.
2. If a firm has no covered orders for the entire quarter, can the firm submit a file that contains the text "no covered orders"?
An XML report must conform to the specification on the SEC web site providing information on how to indicate that there were no covered orders . If the XML file does not conform to the specification, it will be rejected. The SEC provides a sample “empty” report at https://github.com/sec-gov/oh/tree/marked-pdf/samples.
3. Is a firm permitted to submit a Rule 606(a) Report to FINRA for a calendar quarter regardless of whether the firm is required to produce and disseminate a Rule 606(a) report for the applicable quarter?
Yes