Trade Reporting Notice – 1/20/16
OTC Equity Trading and Reporting in the Event of Systems Issues
Firms must establish, maintain and enforce written policies and procedures that include a pre-determined response addressing over-the-counter (OTC) trading and reporting in the event of a systems issue during the trading day (i.e., regular market hours) that prevents the firm from reporting OTC trades within the time frame prescribed by FINRA rules. As discussed below, a firm’s procedures should address the firm’s response to a FINRA facility systems issue, as well as an issue with its own or its vendor’s systems.
Questions regarding this Notice may be directed to: