April 19, 2001
In the February 1, 2001 edition of The OATS Report, the article entitled "Reporting Riskless Principal Executions to OATS" advised firms to use a Reporting Exception Code of "M" prior to the May 7 OATS release and "R" after the new release, whether using the Original Approach to Riskless Principal Trade Reporting (NASD Notice to Members 99-65) or the Alternative Approach (NASD Notice to Members 00-79), to indicate that there is no corresponding trade report in ACT.
Those firms using the alternative approach to riskless principal trade reporting do have the ability to match their OATS Execution Reports to either the "non-tape, non-clearing report" or to the "clearing-only report" by including the Branch/Sequence Number on those reports to ACT. Therefore, firms should only use the Riskless Principal Reporting Exception Code when using the original approach to riskless principal trade reporting.
All firms utilizing the alternative approach must match their OATS Execution Reports to the ACT reports on Issue Symbol, MPID, Branch/Sequence Number, and the Execution Timestamp.
If you have any questions regarding this article or on OATS in general, please call (800) 321-NASD.