Limit Order Display Indicator Renamed Customer Instruction Flag

As announced in the December 15, 2008 OATS Reporting Technical Specifications, the Limit Order Display Indicator on the New Order, Combined Order/Route, Combined Order/Execution and Cancel/Replace reports is being renamed the “Customer Instruction Flag” to better reflect the purpose of the field.  There are no technical changes required by members, nor does the meaning of the field change.  FINRA is only changing the name of the field.

The Limit Order Display Indicator, now called the “Customer Instruction Flag”, indicates whether a firm has received special instructions from a customer to handle a limit order contrary to what is required by SEC Rule 604 (the “Display Rule”).  Accordingly, if a customer specifically requested that the firm not display a non-block, limit order, the firm should populate this field with a “Y” for yes, indicating that it did receive special instructions from its customer with respect to display of the order contrary to what is required by the Display Rule.  Similarly, if a customer specifically requested that the firm display a block size limit order, the firm should also populate the Customer Instruction Flag with a “Y” for yes, indicating that it did receive special instructions from its customer with respect to display of the order contrary to what is required by the Display Rule.

If a member did not receive any special instructions from its customer regarding display of a limit order with respect to the Display Rule, the Customer Instruction Flag should be set to “N”.

FINRA routinely reviews members’ compliance with respect to this field.  As previously stated in NTM 00-26, FINRA uses this field in its automated surveillance for compliance with the requirements of the Display Rule. 

The Customer Instruction Flag continues to be a mandatory field for all orders involving NASDAQ listed equity securities if the limit price is populated.  The Display Rule does not apply to OTC equity securities, therefore the Customer Instruction Flag is not a mandatory field for orders involving OTC equity securities.

Should you have any questions regarding this notice or on OATS in general, please contact the OATS helpdesk at 1-800-321-6273.