OATS Form T

If firms execute in the US a foreign equity security that does not have a US issue symbol, firms must immediately request an issue symbol from NASDAQ in order to satisfy their trade reporting obligations under NASD Rule 6620. In instances where the US issue symbol is not assigned by the end of the trading day, firms must report all applicable OATS information pursuant to NASD Rule 6955 upon receipt of the US issue symbol.
 
The related OATS reports may be reported to OATS via the OATS production system or may be submitted to FINRA on the newly created OATS Form T. The OATS Form T is a pre-formatted Excel spreadsheet available on the OATS Web Interface that may be electronically submitted via email to oats.otc@finra.org for processing by FINRA.  Although the OATS system will accept reports for an order event with an event date prior to the issue symbol effective date, the OATS Form T has been developed to provide firms with an alternative mechanism to submit events to FINRA outside of the regular OATS system. The OATS Form T is available only for events related to orders in foreign securities received and executed prior to the issuance of a US trading symbol.  If firms have fewer than 25 events to report, they must use the OATS Web site, or normal transmission mediums, rather than the OATS Form T to report such order events.

 

Data submitted to OATS with an Order Received Date prior to the symbol issuance date will not be marked late. Firms may, however, be asked to demonstrate that a symbol was promptly requested upon the execution of the trade.

Should you have questions related to the OATS Form T, please contact the OATS Helpdesk at (800) 321-6273.