TRACE FAQ - Agreements & Contracts
Does an introducing broker-dealer that plans to trade and report through a clearing broker-dealer need to sign a TRACE Participant Agreement?
Yes. If a member takes an order, the member has an obligation to report the executed transaction to TRACE. It must report both its activity with the end customer and with the clearing broker/dealer. The clearing broker/dealer and the correspondent (introducing) broker/dealer firm must execute and submit two signed originals of the TRACE Participation Agreement. Under a "give-up" agreement, an introducing broker/dealer does not have to access TRACE directly and may fulfill its obligation to report both the buy trade and sell trade by authorizing the clearing firm to submit both TRACE reports on its behalf.
Important Note: Each correspondent firm must execute an Attachment B, which also must be countersigned by the clearing broker/dealer, and submit the Attachment B to FINRA in order for the third-party reporting arrangement to be valid.
How/where do I get the agreements for TRACE?
All TRACE agreements are posted on the TRACE Web Page.
Note: Whenever possible, FINRA will make all TRACE information accessible online.
How many documents must my firm submit if my firm is self-reporting?
All users of the TRACE system, whether FINRA member firms or third-party reporting intermediaries, must complete and submit a TRACE Order Form indicating the TRACE access method selected as well as two signed originals of the TRACE Participation Agreement.
How many documents must my firm submit if my firm is using a third-party?
FINRA member firms that delegate reporting to a third-party reporting intermediary must complete and sign the TRACE Participation Agreement and TRACE Order Form as well as complete and sign:
If I already have one or more give-up agreements in place for equity reporting, and the same firm(s) will handle my TRACE reporting, do I need to sign additional give-up agreements with these firms for TRACE?
Yes. TRACE has separate agreements.
How do I receive authorization for CUSIP data on TRACE?
Email the information below to CUSIP at: splicense@standardandpoors.com to find out if a daily license is already in place for your firm.
The subject line should read: "Request for Daily License Verification for TRACE Securities"
Firm Name:
Firm Address:
Firm General Phone number:
Firm Contact:
Firm Contact's Role:
Firm Contact's Phone Number:
Firm Contact's Email address:
Level of service to be provided - TRACE Securities List
CUSIP staffers will receive your e-mail and will forward the request to the appropriate sales team member. CUSIP will then send an e-mail directly to FINRA notifying FINRA that your firm has requested TRACE data containing CUSIP numbers and is eligible. Once the daily license has been set up, CUSIP will authorize NASDAQ Subscriber Services to provide access to the files with CUSIP numbers included.
Note: The American Bankers Association has proprietary rights in and to the registered trademark CUSIP® and to the CUSIP® numbers.
If all I want is the FTP file, what agreements do I have to sign?
Anyone wishing to take the FTP file of TRACE-reportable issues must fill out a TRACE Order Form and specifically request permission to access the FTP server. TRACE Participation Agreement (without the attachments) must be completed. In order to see the full list with CUSIP numbers, a daily license must be in place with CUSIP.
Instructions Technical Specifications for downloading the FTP file are available on this site.
How do I download from the FTP Site?
Instructions for downloading the Issue Master file from the secure TRACE Web site can be found in the TRACE User Guide . To download the file via FTP, please see the FTP Download Technical Specification document .
