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INSITE FAQ

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Insite Program

Is INSITE data deemed to be a book or record within the meaning of FINRA Rule 4510?

No, INSITE data is drawn, however, from books and records maintained under securities industry regulations, but is not itself a book or record within the meaning of FINRA Rule 4510.

With whom does FINRA share INSITE data and/or analysis of that data?

  1. NYSE?
  2. Other SROs?
  3. SEC?
  4. Investors involved in SRO arbitrations or other legal proceedings?
  5. Other member firms?
  6. What notice, if any, will firms receive if this is done?

In keeping with current practice regarding data in regulatory systems, FINRA shares INSITE data and analysis with the SEC or other SROs upon request for a legitimate regulatory purpose. When INSITE data is shared with other securities regulators, FINRA does not notify firms of such actions. We do not provide this information to investors in arbitrations or other legal proceedings, nor to other member firms. INSITE data and analysis may be subject, however, to subpoena in legal proceedings.

What infrastructure does FINRA require be in place at self-clearing broker/dealers to respond to inquiries from FINRA staff about INSITE data which the broker/dealer has submitted?

  1. What time frame will FINRA allow for responses to those inquiries?
  2. How frequently does FINRA anticipate making such inquiries?

FINRA deals with firm compliance or designated operational personnel regarding INSITE data in the same way it does with respect to other compliance matters. This is the case not only with the data filed daily, but also with other data from internal FINRA databases on a monthly and quarterly basis.  

To what extent will FINRA ensure that all firms are defining required elements the same so that the submission statistics are not skewed by a firm's interpretation of the data elements and what must be submitted?

Part of FINRA's examination program focuses on data integrity issues not only for daily INSITE filings, but also on other data that underlies such systems as FOCUS, customer complaints, etc.

What steps has FINRA taken to ensure the confidentiality of the data? Possible problems include:

  1. accidental release of the data to the public, including competitors
  2. unauthorized access to the data (i.e., through a computer hacker)
  3. use of the data by FINRA staff after they leave FINRA, particularly in situations where a FINRA staff joins a   member firm and previously had access to all the INSITE data for that firm's competitors for a period of time.

Once data is collected, the system does not transmit data to any external entity.

From an access perspective, the data resides on the FINRA private network with multiple firewall layers. Access to the information is granted only to staff members requiring access via user ID and password.

FINRA has strict policies in effect today regarding the confidentiality of regulatory data and require all employees with access to INSITE data to exert the same care regarding its use that they do today with data in other systems.

Are correspondent clearing firms required to report INSITE data for non-FINRA members and foreign entities?

No, correspondent firms are required to report INSITE data for FINRA members ONLY.

Are correspondent clearing firms required to report INSITE information regarding their own activities, the activities of correspondent firms that carry customer accounts or correspondent introducing firms that do not carry customer accounts?

Clearing firms are required to file data on their own self-clearing activities and on their correspondents. Exemptions may be available for correspondents that do not carry customer accounts.

Are firms that do not carry customer accounts given an exemption from providing INSITE data?

  1. If so, does the exemption apply to both (i) a self clearing firm that only does proprietary trades and does not carry customer accounts; and (ii) a correspondent clearing firm that provides clearing services for a FINRA member who does not carry customer accounts. Any others?

Rule IM-3150 includes an exemptive provision from NASD Rule 3150. Firms are required to request an exemption. 

If we don't clear listed options, do we have to report listed option transaction data?

No, your options clearing firm will report this data on your behalf and INSITE will combine this data with your direct filings. Simply enter zeros in the affected fields.

Some of my firm's correspondents do only listed securities and are NYSE firms. Do these correspondents need to obtain a MPID from FINRA?

The INSITE filing requirements only apply to your correspondents that are FINRA members. Every correspondent for which your firm files must have an MPID.

My firm is a correspondent of one of the major clearing firms. What are our responsibilities for the INSITE program?

If your firm is a correspondent, you are not required to report data to INSITE. Your clearing firm is responsible to report on your behalf. If you don't have an MPID, you need to contact Nasdaq Subscriber Services at (212) 231-5180 opt #3 to have one assigned to your firm.

How can my firm obtain an exemption from Rule 3150?

If a member firm believes the nature of its business may warrant an exemption under IM-3150, it can submit a request via email to [email protected] or via regular mail to the following address:

FINRA Member Regulation
Attn: Regulatory Programs – 3150 Exemption Request
1735 K Street NW
Washington, DC  20016

How should omnibus arrangements for another clearing firm be handled for purposes of INSITE reporting?

Since only the omnibus clearing firm can determine data at the correspondent level, the omnibus firm is responsible for INSITE reporting.

Who is responsible for INSITE filings when a correspondent firm uses multiple clearing firms?

Each clearing firm reports the data it has available on the correspondent. INSITE will combine the data for the correspondent.

For firms that use multiple systems, or a service bureau and in-house system, does the firm need to consolidate the information prior to submission to FINRA or will FINRA consolidate the information utilizing the firm's B/D number?

Multiple organizations can submit data for a broker-dealer and INSITE will consolidate the data.

Can I ask a question via email?

Yes.  Send us an email.


Data

Field Name
Description
Questions & Responses
Processed Date
For the transaction related data elements, this is the same as trade date. For the account related data elements, this is the date on which the summary is calculated.
 
Customer Account
A "customer account" is defined in SEC Rule 15c3-3(a)(1). These are accounts held by retail and institutional customers. For INSITE reporting purposes, firms should exclude "House" accounts and DVP / RVP accounts.
Does the definition of customer account exclude correspondent's accounts identified in Aggregate Net Liquidating Equity? Yes.
Are proprietary trades excluded? Yes.
Are the firm's overseas affiliates considered in this definition? INSITE is targeting the firm's activity with its public customers. We have no jurisdiction over foreign entities doing business with foreign customers.
Trade Count
The number of trades in customer accounts that the correspondent or self-clearing firm had on the processed date.
How should multiple executions of a single order at the same or different prices be counted? Multiple executions of a single order at the same price for the same customer should be reported as a single transaction. Multiple executions of a single order at different prices for the same customer should be reported as a single transaction - average price should be used to calculate price.
Are open-end mutual funds, variable contract, and direct participation program transactions included in the trade counts? No, but closed end fund shares which trade on an exchange are included.
Are ADRs included in the trade counts? Yes. All securities transactions (US or foreign) with domestic customers should be reported. ADRs fall under this definition.
In which reporting category should 144A securities, Portal equity or Debt fall into? The security classification - equity, debt, and options - is the determinant for the reporting category.
Are option exercises/assignments included in this count? The transactions in the underlying securities resulting from the exercise of the option should be included.
Should syndicate trades at the correspondent level be included in the Trade Count reporting requirements? Yes
Should any equity requiring a prospectus be reported? Yes
Should dividend reinvestments be included in the trade counts? No
Are transactions among broker-dealers (street-side trades) reportable in the trade counts? No, only customer transactions (retail and institutional) are reportable.
Aggregate Net Liquidating Equity
The aggregate net liquidating equity in the correspondent’s proprietary accounts. Net liquidating equity is defined as the long market value minus the short market value plus the credit minus the debit for all securities (including options) in the account. The aggregate net liquidating equity is the total net liquidating equity across all accounts.
What does the definition of Aggregate Net Liquidating Equity exclude? The definition of Aggregate Net Liquidating Equity excludes sales credits or commissions, clearing deposit accounts and other receivable/payable accounts
If correspondent firms have both inventory (trading) accounts and investment accounts, how should the two types be treated? Both types of accounts should be included in this calculation.
Who should report ANLE? If a self-clearing firm has no correspondents, they will not report ANLE. This value can be null. If a self-clearing firm has correspondents, they will report ANLE for the correspondents only and not for themselves.
Exchange Code
This is the exchange where the trade was executed. The values for Exchange Code are defined as per the original Bluesheets requirements (NASD NTM 89-17). The codes are used to distinguish between the exchange and the non-exchange set of variables.
A = New York Stock Exchange
B = American Stock Exchange
C = Midwest Stock Exchange
D = Philadelphia Stock Exchange
E = Pacific Stock Exchange
F = Boston Stock Exchange
G = Cincinnati Stock Exchange
K = Chicago Board Options Exchange
L = London Stock Exchange)
M = Toronto Stock Exchange
N = Montreal Stock Exchange
O = Vancouver Stock Exchange
R = NASDAQ (NNM, SC, OTCBB)
S = Over-the-Counter
T = Tokyo Stock Exchange
X = Securities and Exchange Commission.
Z = Other
Which codes are Non-exchange? NASDAQ, OTC Bulletin Board and OTC are non-exchange.
Exchange Trade Count
The number of equity trades in customer accounts executed on a National Securities Exchange, that the correspondent or self-clearing firm had on the "processed date.
What does the definition of a National Securities Exchange include? National Securities Exchange includes NYSE, ASE, PHLX, CBOE, Chicago Stock Exchange, Cincinnati Stock Exchange, Boston Stock Exchange, and Pacific Stock Exchange.
If a correspondent routes an order to another broker-dealer, and that broker-dealer routes the order to an exchange for execution, is that execution considered as "executed on a National Securities Exchange" or as a "Non-Exchange Listed Equity Transaction? "As an execution on a National Securities Exchange
Which category should preferred stock and convertible preferred stock transactions be included? These transactions should be included in the equity category.
FINRA requires Clearing Firms to report prescribed data to FINRA that is used for surveillance purposes. The data requirements are set out in the INSITE Technical Specifications, which require Clearing Firms to file data about transactions. The data must be divided into two categories: (1) Exchange Executions (transactions executed on a national securities exchange) and (2) Non-Exchange Executions (transactions executed in the NASDAQ, OTCBB and other OTC markets). The records I submit to FINRA now include transactions in the NASDAQ Market Center in the second category. Will I be required to change this now that NASDAQ is operational as a national securities exchange?
Until further notice, FINRA will allow firms to report NASDAQ transaction data information as EITHER exchange or non-exchange execution. Firms will be expected to be able to identify which transactions are NASDAQ transactions upon inquiry by FINRA staff.
Exchange Equity Transaction Dollar Value
The total value of equity trades in customer accounts executed on a National Securities Exchange, that the correspondent or self-clearing firm had on the "processed date." The value is simply price times share.
Which transactions are included in the calculation for Dollar Value? The transactions identified (and counted) in the Exchange Trade Count data element should be included for Dollar Value.
Does the Total Value of Transactions reporting requirements include both customer buy and sell transactions? Yes
Exchange Equity Sales Credits / Commissions
The total dollar value of sales credits and/or commissions generated by equity trades in customer accounts executed on a National Securities Exchange, that the correspondent or self-clearing firm had on the "processed date."
Are postage/handling charges excluded from this data element? Yes. This data element is strictly credits and commissions.
Should fee-based payments be included under the Sales Credits and Commissions reporting requirement? Our definition of a fee-based account is one where there is an annual fee regardless of activity. In this context, exclude the fees for the customer accounts. Include the sales credits / commissions. The purpose is to relate compensation to transaction activity. Fee-based compensation is not transaction dependent.
Non-Exchange Trade Count
The number of equity trades in customer accounts executed in a market other than a National Securities Exchange, that the correspondent or self-clearing firm had on the "processed date." The count would include executions in the NASDAQ, OTCBB and OTC markets.
Does this count include 3rd market transactions? Yes
Where should syndicate transactions be included? Yes. Syndicate transactions should be included under Non-Exchange sections.
Are Prime Broker Trades included? Since we do not know where these trades are executed, they should be included here.
FINRA requires Clearing Firms to report prescribed data to FINRA that is used for surveillance purposes. The data requirements are set out in the INSITE Technical Specifications, which require Clearing Firms to file data about transactions. The data must be divided into two categories: (1) Exchange Executions (transactions executed on a national securities exchange) and (2) Non-Exchange Executions (transactions executed in the NASDAQ, OTCBB and other OTC markets). The records I submit to FINRA now include transactions in the NASDAQ Market Center in the second category. Will I be required to change this now that NASDAQ is operational as a national securities exchange?
Until further notice, FINRA will allow firms to report NASDAQ transaction data information as EITHER exchange or non-exchange execution. Firms will be expected to be able to identify which transactions are NASDAQ transactions upon inquiry by FINRA staff.
Options Transactions Count
The number of options transactions in customer accounts, regardless of where the execution took place, that the correspondent or self-clearing firm had on the "processed date."
If a clearing firm executes and clears options transactions for other broker-dealers on an omnibus basis, how are these handled? The underlying principal of Rule 3150 is reporting at the correspondent level. Omnibus Accounts are aggregate accounts and do not disclose the firms. The correspondents will have to report on their own behalf in the instance where they clear on an omnibus basis.
Are futures options included? Futures Options are not included since the CFTC regulates the Futures market and not the SEC.
Does Options Transactions refer to listed options? All Options Transactions are included, regardless of the execution venue.
Should private transactions be included? Yes.
Option Transaction Dollar Value
The total dollar value of options transactions in customer accounts, regardless of where the execution took place, that the correspondent or self-clearing firm had on the "processed date", exclusive of commissions, sales charges, and fees. The value is simply underlying quantity times price.
What should be used for Value? Use Premium Value.
Options Sales Credits/Commissions
The total dollar value of sales credits and/or commissions generated by options transactions in customer accounts, regardless of where the execution took place, that the correspondent or self-clearing firm had on the "processed date."
Should fee based options be excluded? Yes
Debt Transaction Count
The number of transactions in customer accounts for debt issues, regardless of where the executions took place, that the correspondent or self-clearing firm had on the "processed date."
Are convertible bonds included in this count? Yes
Should convertible preferreds be counted as equities? Yes
We assume that definition of debt includes corporate bonds, debentures, U.S. government and agency securities, municipal bonds, asset backed securities, certificates of deposit and foreign government bonds. Is this assumption correct? Yes.
Would the definition of debt include debt derivatives such as CMO's, TIGR's (stripped coupon bonds)? Yes
Are Repos included? No. Since repos are financing transactions, they should not be included in the debt transaction count.
Is commercial paper included as debt? No. Commercial Paper should be counted as cash.
Debt Transaction Dollar Value
The total dollar value of transactions in customer accounts for debt issues, regardless of where the executions took place, that the correspondent or self-clearing firm had on the "processed date."
Is Transaction Dollar Value, principal only or principal plus interest? Principal plus interest.
Debt Transaction Sales Credits / Commissions
The total dollar value of sales credits and/or commissions generated by transactions in customer accounts for debt issues, regardless of where the executions took place, that the correspondent or self-clearing firm had on the "processed date."
 
Number of Customer Accounts with a Securities Position and/or Credit Balance Record
The number of accounts with securities positions or credit balance records maintained for the correspondent or self-clearing firm at settlement as of the "processed date."
Does this include PAIB accounts that are not investment or trading accounts, such as clearing deposits, etc.? No.
Does this include customer accounts with short positions? Or just long securities positions? Both.
If an account has both a credit balance and a security position, is the account counted once or twice? Once.
If a customer has a cash account and a margin account with securities positions. Is both the cash and margin account counted, or is the account counted just once? Customer accounts in the same account number series should only be counted once.
What if the same customer has cash and margin accounts with different account numbers? Different account numbers are defined as different accounts and should be counted separately.
Are guarantee / guarantor accounts included in this category? No.
Margin Debits in Customer Accounts
The total dollar value of margin debits in customer accounts maintained for the correspondent or self-clearing firm at settlement as of the "processed date."
Would this number include the net balance total of all types of margin accounts? Yes.
Should customer margin debits be offset by customer credits for the same customer in other accounts? No. Customer margin debits should be offset by customer credits in sub-accounts with the same account number.
How are margin debits reported? Debits are signed positive; security positions are signed positive for long and negative for short.
Are DVP extensions and unsecureds included? No, since DVP / RVP are primarily institutional and are done in cash accounts.
Aged Initial Margin Calls (RegT)
The total dollar value of initial margin calls in customer accounts maintained by the correspondent or self-clearing firm, that are aged more than 5 business days past the initial call date as of the "processed date."
Does the definition of 'initial margin call' refer to Fed Calls? Yes.
Aged Maintenance Margin Calls (NYSE and FINRA)
The total dollar value of maintenance margin calls in customer accounts maintained by the correspondent or self-clearing firm, that are aged more than 5 business days past the initial call date as of the "processed date."
What is the definition of a FINRA Call? Are you referring to internal 'house maintenance requirements? This term refers to required maintenance margin calls under NYSE and / or FINRA rules. These requirements may differ from "house" maintenance calls.
Short Interest Accounts
The number of customer accounts with uncovered short equity positions maintained for the correspondent or self-clearing firm on the "processed date."
We assume that the definition of short position is one that results from a bonafide "short sale." Is this assumption correct? Yes
We assume that customers who sell short against the box are included in this count. Is this assumption correct? Yes.
We assume that this data element would not include short options and bonds. Is this assumption correct? Yes.
Short Interest Share Count
The number of shares of stock that have been sold short and have not yet been repurchased to close out the short position in the customer account maintained for the correspondent or self-clearing firm on the "processed date."
We assume that this data element will be the sum of the bona fide short sale positions in accounts identified in the previous data element. Is this assumption correct? Yes
Short Interest Dollar Value
The total dollar value of the uncovered short positions in customers accounts maintained for the correspondent or self-clearing firm on the "processed date."
We assume that this data element would be a "market value" based on yesterday's closing price and not the "contract value" of the transaction that created the short position. Is this a correct assumption? Yes
Unsecured Customer Account Debits (T+12 and Later) Settlement Date + 9
The aggregate unsecured net equity for all of the correspondent or self-clearing firm's customer accounts, computed as the dollar value of unsecured and the unsecured portion of partly secured customer accounts T+12 or Later (Settlement Date + 9).
What should be included for unsecured debit? Unsecured debit is a debit balance in a customer account that contains no assets that could be liquidated to cover the debit. This would include debits which result from non-trade related transactions e.g., fees etc.
We are defining partly secured customer account as follows: A debit balance would remain after liquidating all positions in all types of a customer's account (cash and all margin types) based on yesterday's closing price. Is this definition correct? Yes

Do firms need to change the calculation methodology for reporting Unsecured Customer Account Debits due to the change in the standard settlement cycle to T+2 as of September 5, 2017?  No, FINRA is not requiring firms to change their current calculation methodology.  Clearing firms should continue to report based on T+12 or Later or Settlement Date + 9 basis. We understand that after September 5, 2017, this may result in the reporting of the dollar value of Unsecured Customer Accounts as of 11 days (if a firm uses the Settlement Date+9 calculation method) or 12 days (if a firm uses the T+12 calculation method).
Canceled Trade Count
The number of equity trades that the correspondent or self-clearing firm canceled on the "processed date," but executed on an earlier date, where the account number was changed for the transactions. This count can be derived from the details records, but this count can be used to ensure the expected number of records is sent.
Does this count include a cancel/rebill in which the base account number remained the same, and the transaction was canceled for account type only (canceling from cash to margin account)? No. The count should include unrelated account number changes only. Accounts are considered to be related if they are sub-accounts. Cancellations which are rebilled among sub-accounts of the same main account should not be included.
Are same day cancels included? No. Same day cancels should not be included under the Canceled Trade count.
Should trades, which are straight cancelled, be reported? No.
If a trade were cancelled out of one account and rebilled in an another account, should only the cancel record be reported in this field? Yes.
Should cancels for options or debt be reported? No. Canceled Trade Count applies to equity trades only.
As Of Trade Count
The number of equity as of trades (trades not reported on the same day as the execution of the trade) that the correspondent or self-clearing firm processed on the "processed date" where the as of trade date is at least 2 business days before the processed date. The number can be derived from the detail records, but this number can be used to ensure the expected number of records is sent.
Should as of trades for options or debt be reported? No. As Of Trade Counts applies to equity trades

Technical

What are the options for submitting data for INSITE?

There are two options:

  1. FTP via the FINRA private network directly to IFDF, Section 2.1 of the Technical Specification document .
  2. File Upload via the Secure File Transfer Gateway. Secure File Transfer Protocol (SFTP) Interface for Data Intake User Guide .

How does a firm report data in an area where it does not conduct business?

The fields should be left blank. A zero will be interpreted as a value.

Will our correspondent firms be able to view their data by MPID based on what we have submitted on their behalf? If a record has been rejected, will we be able to know which records these are? Will the information be viewable on the Web Site, similar to OATS ?

There are two types of reports available to the File Sending Organization (FSO).

  1. File Validation Report – Once a file is received it is validated for file acceptance. A File Validation Report will be generated and made available to the FSO for every file submitted.
  2. Record Validation Report – After a file is validated, each record within that file is validated in accordance with the record validation requirements. If any record within a file is rejected, the entire file will be rejected. This report will reflect the results of the record validation process, for each validation edit that fails. IFDF will provide the following information:
    • The relative record number in the file.
    • The record key of the record containing the error.

Please refer to Section 3 of the

Technical Specification document

.

From time-to-time, data (e.g., OATS, ACT, etc.) submitted to regulatory organizations must be corrected and resubmitted.

  1. Will firms be required to resubmit corrected data pursuant to the INSITE requirements?
  2. If so, how?

INSITE will accept filings on the day following the "processed date." Rejected files can be resubmitted during this period. When the cause of the rejection is a serious system issue at the filing organization, it may take longer to fix the problem. It will not be necessary to resubmit files once the filing window closes, nor will this be cause itself for disciplinary action. The assumption here is that such events will be non-routine and that the filing organizations will address technical issues promptly.

What measure will FINRA take to ensure that the data that is automatically sent to it through this system is accurate? 

INSITE will process daily data as it is filed. Systematic data integrity issues will be addressed in the traditional on-site examination process or when such issues arise during the review of the reported information.

INSITE requires firms to research and repair their own rejections. To what extent will FINRA issue guidance as to the process for notifying firms of such rejections, the time frame to correct the rejections and whether they must be resubmitted?

The INSITE Technical Specification describes the feedback method on firm filings at Section 3.0. INSITE does not require firms to repair and resubmit rejections after the filing window closes for a day. FINRA does expect filing organizations to take steps to ensure the stability of their filing systems.


Entitlement

What system does the firm use to send INSITE data?

Firms should submit INSITE filing data using either SFTP to directly submit filing data or by uploading a submission file using the Secure File Transfer Gateway. For instructions on uploading submissions, see

Data Intake SFTP Interface User Guide

.

What is the URL for the Secure File Transfer Gateway?

The URL is: https://filetransfer.finra.org.

What is a MPID and how do I obtain one?

MPID is the Market Participant Identifier used to report trades. This is a 4 character alpha code. The Clearing Firms will be reporting INSITE data by MPID. It is necessary to have an active MPID. In order to obtain a MPID, you should contact NASDAQ Subscriber Services at (212) 231-5180 opt #3.

How can I get access to the Secure Filing Transfer Gateway?

You will need SFTP credentials – i.e., an SFTP account. These credentials are just for the SFTP server and are completely separate and distinct from the normal FINRA Enterprise Web Security (EWS) credentials that are used for access to most of FINRA’s web-based applications.

SFTP credentials must be requested by one of your firm’s SAAs. If you cannot identify your SAA, please contact the FINRA Call Center at (800) 321-6273, and select Option 1 for entitlements questions. The operator can help you more easily if you know your firm’s CRD number.

How do I request the Entitlement Forms?

You should call (800) 321-7273 or send an e-mail.

If I have a data related question about INSITE, whom do I contact?

You should send an e-mail .

Does my firm need to delegate and to whom?

If your firm is using a Service Provider to send INSITE data, then you should email [email protected] to delegate filing permissions to the service provider filing on behalf of your firm.

Does my firm need to fill out the Firm Contacts information?

All Clearing Firms and Service Providers need to complete the Firm Contact information prior to being certified for INSITE.