Electronic Blue Sheet Submissions Frequently Asked Questions (FAQ)


See Regulatory Notice 13-38.

 

Large Trader Identification (LTID)

  1. For purposes of the SEC Large Trader Reporting Rule (SEA Rule 13h-1), what is the format of the LTID and the optional suffix?
  2. For purposes of the SEC Large Trader Reporting Rule (SEA Rule 13h-1), how should Unidentified Large Traders be designated?
  3. Is there is a maximum number of LTIDs per account?
  4. If an account has more than three LTIDs, how should this be reported in the Blue Sheets?
  5. If there are no LTIDs, how should the Large Trader Identification 1-3 fields be populated?
  6. How should the Large Trader Identification 1-3 fields be populated when there are no suffixes?
  7. For an Unidentified Large Trader, can the Large Trader Identification field be populated with the eight characters (starting with "ULT"), followed by a dash ("-") and four zeros?
  8. Is there a way within the Blue Sheet Record Layout to distinguish a response to an LTID request versus a conventional Blue Sheet request?
  9. Will there be a new EBS requesting format for LTID?
  10. Should the Unidentified Large Trader number be populated in the Large Trader Identification 1, 2 or 3 field?
  11. Do the Large Trader Identification 1-3, Large Trader Identification Qualifier and Order Execution Time fields need to be included in a firm’s response to an EBS request made after the effective date of these fields for transactions that occurred prior to the effective date of the fields?
  12. When responding to an EBS request from the SEC for Large Trader information, does the firm's EBS submission need to include the Primary Party Identifier and the Contra Party Identifier fields in the record layout?
  13. Will the SEC request Large Trader information from Canadian clearing firms that are not registered in the United States?
  14. Who is responsible for providing the LTID to the executing broker?
  15. As it pertains to Large Trader information, should the executions through the average price account and the allocations from the average price account be included in EBS reporting even if the execution and allocation price are the same?
  16. For the following scenario, what should be reported to the SEC? From January 1 through April 30, a broker-dealer has a customer who is marked as an unidentified large trader.
  17. The Large Trader Identification Qualifier field has a default value of zero. How will the SEC interpret the zero?

 

Execution Time

  1. What time zone should be used for reporting the execution time?
  2. The Blue Sheet Record Layout indicates that the default value for the Order Execution Time field should be dashes "--". Will FINRA and other ISG interested members consider allowing the default value for this field to be blank instead of dashes "--"?
  3. Will FINRA and other ISG interested members consider making the format for the Order Execution Time field similar to the File Creation Time field?

 

Exchange Code

  1. What Exchange Code should be used when an ECN is the execution venue?
  2. What Exchange Code should be used when the London Stock Exchange is the execution venue?

 

Transaction Type Identifiers

  1. Transaction Types "M" for Market-Maker, "N" for Non-Member Market-Maker/Specialist Account and "Y" for Stock Specialist-Assignment were previously associated with options, but are now associated with equity. Is this correct?
  2. For the Transaction Type Identifiers field, should the value of "W" be used to indicate clients who voluntarily declare themselves as a professional customer or should this be a voluntary flag used by the broker-dealer to identify a professional customer?
  3. How will EBS reporting be impacted by the equity values that were removed from the Transaction Type Identifiers field, as noted in FINRA Regulatory Notice 12-47? 

 

Average Price Account

  1. If a client order is facilitated through an “Average Price Facilitation Account,” but the resulting execution of the order is filled through a single execution, should the transaction be reported as “average price”?
  2. If a clearing firm receives a batch file from a firm that consolidates executions and reports them as average price executions, can that same consolidated execution report be submitted on the blue sheets?
  3. If a clearing firm receives a batch file from a firm that consolidates executions, can that same consolidated execution report be submitted on the blue sheets?
  4. Can the executions through the average price account and the allocations to the customer accounts be combined in EBS reporting? 
  5. Can firms report their executions through the average price account as a compressed transaction rather than report the individual average price executions in EBS reporting?

 

Opposing Broker Number

  1. Does the value shown in the Opposing Broker Number field reflect the other side of the firm entering order or the other side of the firm submitting the EBS records?
  2. If a firm does not know the identity of the opposing broker, what should be entered into the Opposing Broker Number field? 

 

Ticker Symbol

  1. The Ticker Symbol field has a default value of blank. However, FINRA will not accept a blank Ticker Symbol field. Will the EBS record layout be changed to reflect this?

 

Contra Party Identifier

  1. If a firm does not know the identity of the contra party, what should be entered into the Contra Party Identifier field?

 

Employer Name

  1. If an account holder has never been employed, what should be populated in the Employer Name field?

 

Requests

  1. For a blue sheet request with multiple issues under the same investigation number, how should the submission be made?
  2. If a firm receives a request for historical data, will the enhanced blue sheet data format be required?
  3. Why will Blue Sheet requests be made on the basis of account number and date?
  4. What criteria will be provided when making a blue sheet request by date range and primary party identifier? 

 

Miscellaneous

  1. Is there a testing period for the enhanced blue sheets?
  2. Will the options symbology requirements now change?
  3. Is EBS reporting required for OTC Options?
  4. Can firms use SIAC to submit Large Trader information to the SEC?
  5. Will there be any requirements specific to FINRA or the other ISG interested members for the new EBS fields?

Large Trader Identification

 

1. For purposes of the SEC Large Trader Reporting Rule (SEA Rule 13h-1), what is the format of the LTID and the optional suffix?
According to the staff of the SEC’s Division of Trading and Markets, an LTID can be a maximum of 13 characters. Specifically, 8 characters for the LTID, followed by a dash, with 4 maximum characters for the optional suffix. As specified in the Instructions to Form 13H, suffixes should initially be limited to three characters. Numbers should be right-justified and zeros should be used in place of blanks.
2. For purposes of the SEC Large Trader Reporting Rule (SEA Rule 13h-1), how should Unidentified Large Traders be designated?
According to the staff of the SEC’s Division of Trading and Markets, for Unidentified Large Traders, broker-dealers should assign their own unique identifying number to each person identified as an Unidentified Large Trader. The number should conform to the format for the LTID and should begin with the letters "ULT". For example, "ULT00001".
3. Is there is a maximum number of LTIDs per account?
According to the staff of the SEC’s Division of Trading and Markets, there is no maximum number of LTIDs per account.
4. If an account has more than three LTIDs, how should this be reported in the Blue Sheets?
According to the staff of the SEC’s Division of Trading and Markets, broker-dealers should submit up to three LTIDs in the Large Trader Identification Number 1-3 fields, and mark the Large Trader Identification Qualifier field with a 'Y'. The firm should keep the additional LTID information with its books and records; and provide this information upon the SEC's request.
5. If there are no LTIDs, how should the Large Trader Identification 1-3 fields be populated?
According to the staff of the SEC’s Division of Trading and Markets, the Large Trader Identification 1-3 fields should be populated with the default value of 13 zeros.
6. How should the Large Trader Identification 1-3 fields be populated when there are no suffixes?
According to the staff of the SEC’s Division of Trading and Markets, the suffix is optional and may be populated by zeros. For example, the Large Trader Identification field can be populated with the eight characters for the LTID which are padded with zeros, followed by a dash ("-") and four zeros for the suffix (e.g. 00000123-0000).
7. For an Unidentified Large Trader, can the Large Trader Identification field be populated with the eight characters (starting with "ULT"), followed by a dash ("-") and four zeros?
Yes. According to the staff of the SEC’s Division of Trading and Markets, the Large Trader Identification field can be populated with the eight characters (starting with "ULT"), followed by a dash ("-") and four zeros (e.g. ULTXY123-0000).
8. Is there a way within the Blue Sheet Record Layout to distinguish a response to an LTID request versus a conventional Blue Sheet request?
No. According to the staff of the SEC’s Division of Trading and Markets, an "X" in the Requester Code field could be an indicator of a Blue Sheet response to an LTID request by the SEC.
9. Will there be a new EBS requesting format for LTID?
No. According to the staff of the SEC’s Division of Trading and Markets, LTID EBS requests will initially be requested on a manual basis.
10. Should the Unidentified Large Trader number be populated in the Large Trader Identification 1, 2 or 3 field?
According to the staff of the SEC’s Division of Trading and Markets, the SEC prefers to have the Unidentified Large Trader number be populated in the Large Trader Identification 1 field.
11. Do the Large Trader Identification 1-3, Large Trader Identification Qualifier and Order Execution Time fields need to be included in a firm’s response to an EBS request made after the effective date of these fields for transactions that occurred prior to the effective date of the fields?
According to the staff of the SEC’s Division of Trading and Markets, the Large Trader Identification 1-3, the Large Trader Identification Qualifier and the Order Execution Time fields must be included in the submission, but these fields can be populated with default values when responding to EBS requests from the SEC after the effective date of the fields for transactions that occurred prior to the effective date.
12. When responding to an EBS request from the SEC for Large Trader information, does the firm's EBS submission need to include the Primary Party Identifier and the Contra Party Identifier fields in the record layout?
Yes. According to the staff of the SEC’s Division of Trading and Markets, when responding to an EBS request from the SEC for Large Trader information, the firm's EBS response must include these new fields in the EBS record layout. However, the firm is not required to populate the fields and may leave the fields with the default values. The SEC will accept any voluntarily submitted values for such fields.
13. Will the SEC request Large Trader information from Canadian clearing firms that are not registered in the United States?
According to the staff of the SEC’s Division of Trading and Markets, SEA Rule 13h-1 indicates that recordkeeping and reporting provisions only apply to U.S. registered broker-dealers.
14. Who is responsible for providing the LTID to the executing broker?
According to the staff of the SEC’s Division of Trading and Markets, pursuant to SEA Rule 13h-1(b)(2), each Large Trader is responsible for disclosing to the U.S. registered broker-dealer effecting transactions on its behalf its LTID and for each account to which it applies.
15. As it pertains to Large Trader information, should the executions through the average price account and the allocations from the average price account be included in EBS reporting even  if the execution and allocation price are the same?
According to the staff of the SEC's Division of Trading and Markets, the Average Price Account field must be populated and the allocated trades must be reported in EBS even if the execution and allocation price are the same. In response to traditional (non-Large Trader) EBS requests from FINRA and other ISG interested members, the Average Price Account field also must be populated and the allocated trades also must be reported in EBS even if the execution and allocation price are the same.
16. For the following scenario, what should be reported to the SEC? From January 1 through April 30, a broker-dealer has a customer who is marked as an unidentified large trader. On May 1, the customer gives the broker-dealer its LTID number. On December 1, the SEC requests LTID information regarding the customer for the month of February.
According to the staff of the SEC’s Division of Trading and Markets, when a broker-dealer has a customer that previously was an Unidentified Large Trader (e.g., ULT45678), and the customer subsequently registers with the SEC and obtains an LTID number (e.g., 12345678), the broker-dealer would track the customer according to the LTID number from the time that the customer provides the LTID number to the broker-dealer. In this specific scenario, in response to a request for LTID data from February (e.g., where the SEC requested data for “12345678” specifically or where the request was for transaction records generally), the broker-dealer should report transaction records for its customer using the firm’s designated number (ULT45678) for the February data.
17. The Large Trader Identification Qualifier field has a default value of zero. How will the SEC interpret the zero?
According to the staff of the SEC’s Division of Trading and Markets, firms should use this field to qualify if more than three LTIDs exist for a transaction by marking “Y” for yes. Otherwise, firms should mark the field “N” for No (if there were three or less LTID or no LTID existing for the transaction). However, if a firm does not know and the firm leaves the default value of zero for the Large Trader Identification Qualifier field, the SEC will interpret it as a "No".  

Execution Time

 

1. What time zone should be used for reporting the execution time?
Execution time should be reported in Eastern Time. Firms must synchronize their time clocks with the atomic clock every business day before market open. To maintain clock synchronization, clocks should be checked against the standard clock and re-synchronized, if necessary, at pre-determined intervals throughout the day. The reported time must be reported in a 24-hour format as HHMMSS. A firm must ensure that the business clocks it uses are accurate to within one-second of the National Institute of Standards and Technology Atomic Clock in Boulder Colorado (NIST Clock) or the United States Naval Observatory Master Clock in Washington, D.C., (USNO Master Clock) and must immediately recalibrate its clocks if the drift is greater than one second. This includes all of the following:
  1. the difference between the NIST/USNO standard and a time provider’s clock;
  2. transmission delay from the source; and
  3. the amount of drift of the firm’s business clock.
A firm’s written supervisory procedures must include a description of how the firm conducts, documents and maintains synchronization of its business clocks.
2. The Blue Sheet Record Layout indicates that the default value for the Order Execution Time field should be dashes "--". Will FINRA and other ISG interested members consider allowing the default value for this field to be blank instead of dashes "--"?
The default value for the Order Execution Time field is two dashes "--" (not six dashes).There will be no change to the format of the Order Execution Time field.
3. Will FINRA and other ISG interested members consider making the format for the Order Execution Time field similar to the File Creation Time field?
The File Creation Time field is HH:MM:SS with a field length of eight and the Order Execution Time field is HHMMSS with a field length of six. There will be no change to the format of the Order Execution Time field.

Exchange Code

 

1. What Exchange Code should be used when an ECN is the execution venue?
If the identity of the exchange is known, then use the appropriate Exchange Code. If the identity of the exchange is not known, then ECN trades should be coded as "Z" for "Other".
2. What Exchange Code should be used when the London Stock Exchange is the execution venue?
The Exchange Code value for the London Stock Exchange is "L". This was inadvertently excluded in Regulatory Notice 11-56, but has been included in Regulatory Notice 12-36.

Transaction Type Identifiers

 

1. Transaction Types "M" for Market-Maker, "N" for Non-Member Market-Maker/Specialist Account and "Y" for Stock Specialist-Assignment were previously associated with options, but are now associated with equity. Is this correct?
No. Transaction Types "M" for Market-Maker, "N" for Non-Member Market-Maker/Specialist Account and "Y" for Stock Specialist-Assignment are associated only with options. This was inadvertently miscategorized in Regulatory Notice 11-56, but has been corrected in Regulatory Notice 12-36.
2. For the Transaction Type Identifiers field, should the value of "W" be used to indicate clients who voluntarily declare themselves as a professional customer or should this be a voluntary flag used by the broker-dealer to identify a professional customer?
The value of "W", which is associated with options under the Transaction Type Identifiers field, should be used to indicate clients who voluntarily declare themselves a "Voluntary Professional". It is the client’s responsibility to identify the trade as such. In addition, an exchange may define what it considers to be a “Voluntary Professional.”  For example, CBOE Rule 1.1(fff) defines “Voluntary Professional.”
3. How will EBS reporting be impacted by the equity values that were removed from the Transaction Type Identifiers field, as noted in FINRA Regulatory Notice 12-47?
The equity values removed from the Transaction Type Identifiers field will no longer be required for NYSE's trade reporting purposes. In turn, these equity values will not be passed onto EBS reporting. Refer to NYSE Information Memorandum 12-25 for further details.

Average Price Account

 

1. If a client order is facilitated through an “Average Price Facilitation Account,” but the resulting execution of the order is filled through a single execution, should the transaction be reported as “average price”?
Yes, this execution should be reported as “average price.”
2. If a clearing firm receives a batch file from a firm that consolidates executions and reports them as average price executions, can that same consolidated execution report be submitted on the blue sheets?
No, the underlying executions must be reported. Even if a clearing firm is batch processing aggregate and/or consolidated execution information for continuous net settlement purposes, the underlying trades that were reported to the tape must be reported on the blue sheets. Firms that are unable to provide the underlying trade information must inform FINRA of this before submitting a blue sheet.
3. If a clearing firm receives a batch file from a firm that consolidates executions, can that same consolidated execution report be submitted on the blue sheets?
No, the underlying trades that were reported to the tape must be reported on the blue sheets. Firms that are unable to provide the underlying trade information must inform FINRA of this before submitting a blue sheet.
4. Can the executions through the average price account and the allocations to the customer accounts be combined in EBS reporting?
No. Firms should report the executions through the average price account with a "2" in the Average Price field (whereby a "2" represents the average price account itself) and the allocations to the customer accounts with a "1" in the Average Price field (whereby a "1" represents the recipient of the average price transaction). The executions and allocations must be separate entries in EBS reporting.
5. Can firms report their executions through the average price account as a compressed transaction rather than report the individual average price executions in EBS reporting?
No. Firms must report the individual executions through their average price account.

Opposing Broker Number

 

1. Does the value shown in the Opposing Broker Number field reflect the other side of the firm entering order or the other side of the firm submitting the EBS records?
The Opposing Broker Number field should reflect the NSCC clearing house number of the broker-dealer on the other side of the executed trade as it is reflected in the trade report.
2. If a firm does not know the identity of the opposing broker, what should be entered into the Opposing Broker Number field?  
If the firm does not know or cannot determine the identity of the clearing firm, then the Opposing Broker Number field should be populated with the default value. For example, if a firm routes an order to an exchange for execution and the firm does not know or cannot determine the NSCC clearing number or OCC clearing number of the broker on the other side of the trade, then the Opposing Broker Number field should be populated with the default value.

Ticker Symbol

 

1. The Ticker Symbol field has a default value of blank. However, FINRA will not accept a blank Ticker Symbol field. Will the EBS record layout be changed to reflect this?
No. The default value for the Ticker Symbol field will remain as a blank. A firm must populate the Ticker Symbol field with the value that was provided to it by the requesting regulator. For example, FINRA will provide the 9 digit CUSIP number when requesting EBS information for bonds. The firm's EBS response must contain the first eight digits of the CUSIP number in the Ticker Symbol field. The field length of the Ticker Symbol field is 8 digits, so it will only accommodate the first eight digits of the CUSIP number.

Contra Party Identifier

 

1. If a firm does not know the identity of the contra party, what should be entered into the Contra Party Identifier field?
If a firm does not know or cannot determine the identity of the contra party, then the Contra Party Identifier field should be populated with the default value. For example, if a firm routes an order to an exchange for execution and the firm does not know or cannot determine the contra party to the trade that is represented by the Opposing Broker Number field, then the Contra Party Identifier field should be populated with the default value.

Employer Name

 

1. If an account holder has never been employed, what should be populated in the Employer Name field?
If an account holder is a natural person who has never been employed, then the Employer Name field should be populated with its default value.

Requests

 

1. For a blue sheet request with multiple issues under the same investigation number, how should the submission be made?
FINRA and the ISG interested members will accept multiple symbols submitted under one investigation number. Firms can also submit blue sheets using each symbol and produce separate records for each symbol. It is recommended that firms submit the blue sheet combining all symbols on one blue sheet submission to reduce the overall number of submissions.
2. If a firm receives a request for historical data, will the enhanced blue sheet data format be required?
No, the enhancements will be required for data beginning November 30, 2012. Requests for older data will not require submission of enhanced blue sheet data elements.
3. Why will Blue Sheet requests be made on the basis of account number and date?
Requesting Blue Sheet data by account number and date will reduce data submission size.
4. What criteria will be provided when making a blue sheet request by date range and primary party identifier?
When making an EBS request by date range and primary party identifier, the requestor will provide one or more of the following criteria for purposes of identifying the primary party: Market Participant Identifier (MPID), Central Registration Depository (CRD) number and/or Options Clearing Corporation (OCC) number. The firm's response should reflect the criteria.

Miscellaneous

 

1. Is there a testing period for the enhanced blue sheets?
Yes, the testing period starts on November 1, 2012.
2. Will the options symbology requirements now change?
No, the symbol field must contain OPTIONXX when Record 6 contains option data. If the symbol field does not contain OPTIONXX, Record 6 should be set to its default values in FIELD POSITIONS 2 through 80, and then add Record Sequence Number Seven. Please refer to the prior Blue Sheets Options Symbology (OSI) requirements in Regulatory Notice 09-18.
3. Is EBS reporting required for OTC Options?
Yes. Following the implementation of the Option Symbology Initiative, new fields pertaining to options were added to the EBS record layout. EBS information for OTC Options must be provided upon request. Please refer to the prior Blue Sheets Options Symbology (OSI) requirements in Regulatory Notice 09-18.
4. Can firms use SIAC to submit Large Trader information to the SEC?
Yes. According to the staff of the SEC’s Division of Trading and Markets, responses to the SEC's Large Trader EBS requests can be sent through SIAC.
5. Will there be any requirements specific to FINRA or the other ISG interested members for the new EBS fields?
No. Unlike the “Transaction Codes” fields, there are no requirements specific to FINRA or the other ISG interested members for the new EBS fields.

 

    Last Updated: 11/4/2013