In a Trade Reporting Notice dated February 22, 2008, FINRA announced that it had modified the TRACE system to accept equity CUSIPs1, and reminded 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 also reminded 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.
Effective August 4, 2008,modifications to the TRACE system will allow firms to more easily meet certain of the reporting requirements set forth in the February 22, 2008 Notice.2 FINRA will issue a Technical Notice detailing the system changes and the impact to member firms and data vendors.
1 CUSIP stands for Committee on Uniform Securities Identification Procedures and is a registered trademark of Standard and Poor's, Inc. (S&P). Each security is assigned a unique CUSIP by a service administered by S&P. The configuration of an equity CUSIP differs from a debt CUSIP. When the TRACE System was built, it was not designed to accept equity CUSIPs.
2 Until the modifications are effective, member firms should report transactions in TRACE eligible securities with equity CUSIPs to Market Regulation via e-mail to the firstname.lastname@example.org mailbox or via Paper Form T.
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