Trade Reporting Notice – 1/20/16

OTC Equity Trading and Reporting in the Event of Systems Issues

Executive Summary

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:

  • Dave Chapman, Director, Market Regulation, at (240) 386-4995; or
  • Brendan Loonam, Director, Business Services, at (212) 858-4203; or
  • Lisa Horrigan, Associate General Counsel, Office of General Counsel, at (202) 728-8190.