Transparency Services Legal Agreements
FINRA member firms that have an obligation to report over-the-counter secondary market transactions in eligible equity and fixed income securities must submit their transaction reports to the appropriate FINRA facility. The facilities covered by the following agreements and documentation include:
- TRACE (Corporate and Agency; Securitized Products; and Treasuries)
- OTC Reporting Facility (ORF)
- Alternative Display Facility (ADF)
The following provides guidance on the steps for accessing one or more of the facilities.
Required Documentation – all facilities
The FPA is used to add a new FINRA product, delete an existing product, update the firm’s clearing relationships or update the firm’s contact information.
- FINRA has updated its equities and fixed income transparency facilities FINRA Transparency Services Participation Agreement (FPA to version 1.4 replacing the existing FPA version 1.3a)
- In addition to updating certain definitions and contract terms, FINRA has modified the procedure for executing the agreement. While the agreement is available for download and review, the method of execution and submission has changed. Going forward, a member firm must use the FPA Form via the FINRA Firm Gateway (Firm Gateway) to execute and submit the agreement. Access to the Firm Gateway and FPA Form is provided by your firm’s Super Account Administrator (SAA).
- Firms that currently have an FPA on file with FINRA and need to add a new FINRA product or MPID, delete an existing product or MPID, or update the firm’s clearing relationships or contact information must also use the FPA Form via the Firm Gateway.
Posting of the revised FPA serves as notice of this change. The posting date is indicated by the date shown next to the agreement or amendment. Member firm participants that currently have an FPA on file with FINRA are not required to re-execute the agreement. The modified FPA will go into effect 90 days after the posting of this notice and will be binding on existing participants.
Existing participants will have 30 days after the posting date to opt out of the revised FPA or will be deemed to have agreed to and accepted the revised FPA. Existing participants that opt out of the revised FPA will lose access to all products covered under the FPA. Firms should notify FINRA of their intention to opt out in accordance with the notice provisions under the FPA.
Other Documentation—all facilities, or as specified
TRACE Order Form
The TRACE Order Form is used by a member firm to add, modify or delete users in the TRAQS web application as well as a Web API certificate to access the master files of active securities. If requesting access containing identifiers issued by CUSIP Global Services, a firm must have the appropriate product license in place with CUSIP Global Services. Please allow 2 business days for processing.
FINRA Transparency Services Uniform Service Bureau/Executing Broker Agreement (USA)
The USA allows a member firm to report trades on behalf of another FINRA member to the relevant facility. The fully executed agreement must be on file with FINRA prior to submitting trades on behalf of another firm.
- TRACE: The TRACE New Issue Form is used by a member firm to comply with FINRA Rules 6760 (Underwriter Obligation to Provide Notice) or 6730 (Transaction Reporting).
- ORF: The TRACE New Issue Form may be used by a member firm to request an OTC symbol in support of compliance with FINRA Rule 6622 (Transaction Reporting).
The FINRA Transaction Fee Transfer Agreement
The FINRA Transaction Fee Transfer Agreement applies to FINRA members and their respective clearing firms that choose to utilize FINRA Facilities to transfer a transaction fee on transactions reported to the Alternative Display Facility (ADF), the FINRA/NASDAQ TRF, the FINRA/NYSE TRF, or the OTC Reporting Facility (ORF). See Rules 7130(h), 7230A(h), 7230B(i), and 7330(i).
Other Documentation – ORF only
ORF Web Access Agreement
The ORF Web Access Agreement provides access to ORF reference data files via API Server.
Required Documentation – ADF only
Questions on executing or submitting any of the forms listed above may be directed via email to FINRA Market Operations or phone