ORF Step In/Step Out Trades

Recently, FINRA has been made aware of an Over The Counter Reporting Facility (ORF) technical issue regarding the confirmations firms receive from DTCC for step-in/step-out trades.

On all step in/step out trades, DTCC expects the step in/step out indicator from the seller's perspective of the trade. However, in cases where the trade is entered as a Buy step in/ step out, and subsequently Matched By Acceptance, Auto-Locked, or was Locked-In At-Entry, FINRA is sending the indicator to DTCC as it was reported to ORF, i.e. from the buyer's perspective.

Between November 17, 2014 and March 4, 2016, FINRA estimates there have been approximately 11,600 Matched By Acceptance trades, approximately 5,300 Matched by Auto-Locked trades, and approximately 3,350 Locked-In-At-Entry trades affected by this issue.

FINRA will issue an additional ORF technical notice with further details on the implementation of a fix for this issue. FINRA does not require or recommend any action to be taken by firms to attempt to correct this issue.