Regulatory Notice 09-21

FINRA Adopts Amendments Relating to Reporting Transfers of Proprietary Positions in Debt and Equity Securities in Connection With Certain Corporate Control Transactions; Effective Date: May 4, 2009

Executive Summary

Effective May 4, 2009, firms are not required to report to FINRA for purposes of publication transfers of proprietary positions in debt and equity securities between a member firm and another member firm or non-member broker-dealer under certain specific conditions, as outlined in this Notice.

The text of the amendments can be found at


Questions regarding this Notice may be directed to:


  • The Legal Section, Market Regulation, at (240) 386-5126; or
  • The Office of General Counsel at (202) 728-8071.


The process for transferring debt positions described in this Notice was updated on July 30, 2012. For transfers of debt positions, firms must first request that FINRA Operations enable their reporting Market Participant Symbol (MPID) for position transfer entry by contacting FINRA Operations at (866) 776-0800 or by email. See the applicable technical specifications for FIX, CTCI and Web on the TRACE Documentation page.