Trade Reporting Notice - February 22, 2008

FINRA Announces Modifications to the TRACE System Relating to Certain Securities with Equity CUSIPs and Reminds Firms of Their Reporting Obligations Regarding Equity-Linked Notes and Convertible Debt

Executive Summary

FINRA has modified the TRACE System to accept equity CUSIPs, and reminds member firms that they must report transactions to TRACE in securities that are "TRACE-eligible securities," such as unlisted convertible debt, unlisted equity-linked notes and similar debt securities. FINRA reminds firms that only unlisted convertible debt and unlisted equity linked notes are treated as debt for purposes of trade reporting; convertible debt and equity-linked notes that are listed on a national securities exchange must be reported to the appropriate equity trade reporting facility.