Trade Reporting Notice – 1/22/19

TRACE Reporting of OTC Transactions in Listed Bonds

FINRA is issuing this Notice to remind members of their TRACE reporting obligations with regard to over-the-counter transactions in TRACE-eligible securities that may also be listed on an exchange. Rule 6730 generally requires members to report to TRACE transactions in TRACE-eligible securities within the period of time prescribed by the rule. Rule 6730(e) provides exceptions for certain transactions, including transactions in TRACE-eligible securities listed on an exchange. Specifically, Rule 6730(e)(2) excepts from the TRACE reporting requirements transactions that are listed on a national securities exchange, when such transactions are executed on and reported to the exchange and the transaction information is disseminated publicly. However, unless another exception is available, where these transactions occur over the counter, members are required to report these transactions to TRACE if the security involved meets the definition of “TRACE-Eligible Security.” We note that over-the-counter transactions in a non-U.S. dollar-denominated debt security that is listed on a national securities exchange are not reportable to TRACE because they are not within the scope of “TRACE-Eligible Security.”

Questions regarding adding a new security for TRACE reporting may be directed to FINRA Market Operations at (866) 776-0800. Legal or interpretive questions may be directed to Racquel Russell, Associate General Counsel, Office of General Counsel (OGC), at (202) 728-8363.