Exemptive Relief from the OATS Recording and Reporting Requirements Pursuant to FINRA Rules 7470 and 9610
FINRA Rule 7470 contains a provision that permits FINRA to grant exemptive relief from the OATS reporting and recording requirements for manual orders in certain circumstances, for example, where reporting of such information would be unduly burdensome for the member or where temporary relief from the rules would permit the member to avoid unnecessary expense or hardship (in the form of additional time to achieve compliance).
Firms that meet all of the following criteria are eligible to request an exemption:
Any exemptive relief granted would be for a period of no longer than two years. At or prior to the expiration of a grant of exemptive relief, members continuing to meet the criteria specified above may request a subsequent exemption.
To formally request exemptive relief, please complete and submit the following request form (PDF 26 KB) via fax, email or regular mail, along with supporting documentation, to the following address:
FINRA, Market Regulation Department/OATS
9509 Key West Avenue
Rockville, MD 20850
Email: OATS Phase III
With a copy to:
FINRA, Regulation and Policy Oversight Office of General Counsel
1735 K Street, NW
Washington DC 20006
Attention: Matthew Adeola