Pandemic/Business Continuity Planning for FINRA Reporting Facilities
In light of the recent outbreak of coronavirus disease (COVID-19), FINRA continues to review its pandemic and business continuity plans to ensure continuous operation of FINRA’s facilities for the reporting of OTC transactions in equity and fixed income securities (i.e., the Alternative Display Facility (ADF), the OTC Reporting Facility (ORF), the Trade Reporting and Compliance Engine (TRACE) and the FINRA Trade Reporting Facilities (TRFs), operated on FINRA’s behalf by the TRF Business Members1) (collectively, the “FINRA Facilities”). FINRA anticipates that the FINRA Facilities will remain fully operational in the event of a pandemic.
Firms are reminded of FINRA’s guidance relating to back-up facilities in the unlikely event that FINRA declares a widespread systems outage with respect to one of the TRFs or the ADF. Firms are also reminded that they must establish, maintain and enforce written policies and procedures that include a pre-determined response addressing OTC trading and reporting in the event that they experience a systems issue in their own systems or in a vendor’s systems. See Trade Reporting Notice 1/20/16 (OTC Equity Trading and Reporting in the Event of Systems Issues) and Trade Reporting Frequently Asked Questions, Section 206 (Trade Reporting in the Event of Systems Issues).
1. FINRA has confirmed with the TRF Business Members that they also are reviewing their pandemic and business continuity plans to ensure continuous operation of the TRFs.