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Firms Capturing Time in Milliseconds Required to Report to OATS in Milliseconds Beginning April 7, 2014

On February 27, 2014, the SEC approved FINRA's proposed rule filing SR-FINRA-2013-050. The approved amendment to the OATS rules requires firms to express time in milliseconds when reporting order information to OATS if the firm's systems capture time in milliseconds, effective April 7, 20141. However, firms are not required to capture time in milliseconds. Further, if their systems do not capture milliseconds, they are permitted to continue to report time to the second.

For purposes of recording and reporting information to OATS, FINRA Rule 7440 currently requires firms to record order event times in hours, minutes and seconds (i.e., HH:MM:SS).2 When OATS was expanded to include all NMS stocks in 2011, FINRA published guidance stating that firms that capture time in milliseconds should report time to OATS in milliseconds (i.e., HH:MM:SS:mmm).3 This approved amendment to the OATS Rules codifies the 2011 guidance.

Firms should note that other components of this rule filing related to equity trade reporting will be implemented at a later date to be announced in a Regulatory Notice.

1 See Securities Exchange Act Release No. 71623 (February 27, 2014), 79 FR 12558 (March 5, 2014) (Order approving SR-FINRA-2013-050).

2 See Rule 7440(a)(2). Rule 7450 generally requires all applicable order information required to be recorded under Rule 7440 to be reported to OATS.

3 See Regulatory Notice 11-03 (January 2011); see also OATS Reporting Technical Specifications, Cover Memo, at iv (May 3, 2011 ed.). The amendments codify this guidance into Rule 7440(a)(2).