Regulation Filing Applications Instructions
Pursuant to FINRA Rule 4560, member firms are required to report total short positions in all customer and proprietary firm accounts in all equity securities to FINRA on a bi-monthly basis. These filings are made online via the Regulation Filing Applications (RFA) system at https://regfiling.finra.org.
All firms that report short interest to FINRA are responsible for maintaining current and previous-cycle short interest reports pursuant to SEC recordkeeping requirements. The RFA system is the only method for reporting the firm’s proprietary and customer short positions in NASDAQ, NYSE, NYSE MKT, NYSE Arca, BATS, and OTC equity securities. If your firm notes any discrepancies in the filing of its short interest report or has any reporting questions, please contact Jocelyn Mello-Gibbon at (240) 386-5091 or Lauren Zito at (240) 386-5432. Please direct questions about entitlement or access to the system to your firm’s account administrator. If you do not know who your account administrator is, please contact the FINRA Call Center at (301) 590-6500.
Member firms that have short positions in OTC equity securities and in securities listed on a national securities exchange, such as NASDAQ, NYSE, NYSE MKT, NYSE Arca, and BATS must file a Short Position Report with FINRA via the Web-based RFA system. The application will accept filings for the current reporting period as of 8 a.m. Eastern Time (ET) on the designated settlement date.
Each member firm must file a Short Position Report with FINRA for each reporting period to report total short positions for all customer and proprietary accounts maintained at the firm.
The Reporting Period: Firms must report their mid-month short positions as of the close of business on the settlement date of the 15th of each month or, where the 15th is a non settlement date, on the preceding settlement date. Firms must report their end-of-month short positions as of the close of business on the last business day of the month on which transactions settle.
The Filing Date: Filings must be received by FINRA by 6:00 p.m., ET, on the designated due date, which is the second business day after the designated settlement date.
Short Interest Reporting: Short positions for all firm accounts, including those for the firm’s partners/officers, employees and customers must be reported. The report should list, in alphabetical order, the relevant exchange/market code, issue symbol, security name, and number of common shares, preferred shares, warrants, units or ADRs short for the current reporting period as of the designated settlement date. Firms should report only whole numbers of shares, and not decimals or fractional shares.
Firms are required to designate the appropriate exchange or market code, as of the designated settlement date, for each issue symbol and short position reported.1 Firms must append the appropriate exchange or market code to the corresponding issue symbol that represents the primary exchange or market on which the security is listed in the United States as of the designated settlement date.2 Currently, the only exchange/market codes that will be accepted by RFA are as follows:
|A||New York Stock Exchange|
Issue symbols should be verified to ensure that they reflect the security’s NASDAQ, NYSE, NYSE MKT, NYSE Arca, BATS or OTC equity symbol as of the relevant settlement date. Issue symbols and names can be verified by accessing symbol directories on the website of the relevant exchange.
Prior to submitting a short interest position in an equity security, member firms must remove all spaces, special characters and lowercase letters from the issue symbol, as they are not currently accepted by RFA. Refer to the table below for some examples.
|Issue symbol with spaces/special characters||Issue symbol to be reported through RFA|
In addition, please be aware of the following concerning short positions in new issues: Syndicate balances that do not represent short positions and short positions in syndicate accounts that will be covered from over allotment provisions related to the offering of that issue should be excluded from short interest reporting. Member firms are advised to establish, maintain and enforce written supervisory procedures regarding firm underwritings so as to avoid any occurrence of inaccurate reporting of this type, particularly where a member firm relies on a system-generated short interest report.
How to file: Short Position Reporting
The RFA system was developed to provide member firms with an efficient method to report NASDAQ, NYSE, NYSE MKT, NYSE Arca, BATS, OTC equity and other exchange-listed short positions.
Firms have the option of transmitting short positions either by completing the system-generated form or by uploading a file containing the short positions to the Web-based application. Firms may also use a service provider to file the short interest report on their behalf.
The system configuration requirements are as follows.
- Requires a browser supporting 128-bit encryption for the SSL connection.
- Users must be able to save encrypted files to a disk to open/save any files downloaded from the site.
FINRA Upload Format
The FINRA record format uses four types of records. There should be only one occurrence of Record Types 1, 2 and 4 for each SHORT Filing (or within the submitted file if a firm or service provider sends multiple filings in a single file). Record Type 3 is used to report each short position.
Note: If a firm or service provider submits multiple filings in a single file, and any of the filings are rejected, the status of the job will show as Rejected (even if four out of five filings are accepted). It is the firm’s responsibility to make sure that all filings are submitted correctly each filing period.
Record Type 1 - Firm Identification Record
Record Type 1 must always be the first row in the record submitted to FINRA. Firms must populate the first field in Record Type 1 with “A1.” Firms must also populate the SEC number and the firm number fields. These numbers must be correct or the file will be rejected.
|1||ID 1||CHAR||2||1-2||"A1"||Must have the code "A1" to identify the record type|
|2||Firm Name||CHAR||30||3-32||Name of the firm reporting the short position|
|3||Firm Number||NUMBER||6||33-38||Firm Number (may be the CRD #, FINRA # or Broker/Dealer #)|
|4||SEC Number||NUMBER||5||39-43||XXXXX||SEC Number (do not include the "8-" prefix)|
|6||Prepared By||CHAR||25||48-72||Name of the person to contact at the firm|
Record Type 2 - Firm Contact Record
Record Type 2 must always be the second row in the record submitted to FINRA. Firms must populate the first field in Record Type 2 with "A2."
|1||ID2||CHAR||2||1-2||"A2"||Must have the code "A2" to identify the record type|
|2||Contact Number||NUMBER||12||3-14||nnn-nnn-nnnn||Telephone number at firm (include the dashes)|
|3||Contact Extension||NUMBER||4||15-18||Telephone extension number|
|4||Contact Title||CHAR||25||19-43||Title of the Contact Person|
|5||Settlement Date||DATE||6||44-49||mmddyy||Settlement date|
|6||Trade Date||DATE||6||50-55||mmddyy||Trade date|
|7||CBOE DEA||CHAR||1||56-57||"Y"||Enter "Y" if CBOE is the firm's designated examining authority|
Record Type 3 - Short Interest Data
One record of this type must be created for each short position. Firms must populate the first field in this record with the letter "B" followed by a blank space. Record Type 3 will begin at row three.
|1||ID3||CHAR||2||1-2||"B "||Must have the code "B " (the letter "B" followed by a space) to identify the record type|
|2||Exchange||CHAR||1||3||The code supplied should represent the U.S. primary exchange or market on which the security is listed as of the designated Settlement Date|
|2||Symbol||CHAR||10||4-13||Symbol for the security, left justified|
|3||Security Name||CHAR||30||14-43||Name of the security, left justified|
|4||Position||NUMBER||9||44-52||Short position for the security, right justified|
Record Type 4 - Trailer Record
Record type 4 must contain data identifying the total number of records in the file. The first field in this record should always be "99." Record type 4 is always the last row in the record.
|1||ID4||CHAR||2||1-2||"99"||Must have the code "99" to identify the record type|
|2||Total Records||NUMBER||5||3-7||Total number of records in the file, including the header records, but excluding the trailer record. This should be right justified.|
Example Short Position Filing:
A1ACME SECURITIES, INC. 012345099991111JOE SMITH
A2202-555-1114 VICE PRESIDENT 101598101298
B RABCD ALPHABET SOUP CO. 000015500
B BXYZ END OF THE LINE INC. 000009950
A1ABCD SECURITIES, INC. 543210000023333JOE BROWN
A2111-555-0000 VICE PRESIDENT 101598101298
B RABCD ALPHABET SOUP CO. 000015500
B BXYZ END OF THE LINE INC. 000009950
Note: If a firm or service provider submits multiple filings within a single file, the submitting entity MUST have been delegated privileges by each firm for which it is submitting data. In this example, if firm 012345 submits two filings, one for itself and one for firm 543210, then firm 543210 MUST Delegate SHORTS WRITE access to firm 012345. Delegation can only be performed by a firm's Regulation Filing Applications Account Administrator.
1 See Notice to Members 06-20 for a more detailed description of the RFA system requirements.
2 It is important to note that the exchange or market on which the short sale transactions that comprise the short interest positions were executed is not relevant and should not be considered.