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Technical Notice

OATS Reporting Non-FINRA Member Firm List

May 27, 2016

Beginning August 1, 2016, firms that report information to OATS will be required to include on their reports the identity of U.S.-registered broker-dealers that are not FINRA members and broker-dealers that are not registered in the U.S. but have received an SRO-assigned identifier. The identities may be reported using either the broker-dealer’s Central Registration Depository (CRD®) number or an SRO-assigned identifier. FINRA will provide a list of all acceptable CRD numbers for firms to use to facilitate compliance with the new requirements.

The rule does not mandate which identifier reporting members must use. If a broker-dealer that must be identified does not have an SRO-assigned identifier, the reporting member receiving the order must report the firm’s CRD number. Similarly, for a non-U.S.-registered broker-dealer that has been provided with an SRO-assigned identifier to access a FINRA trade reporting facility pursuant to FINRA Rule 7220A or 7320 but does not have a CRD number, the reporting member receiving the order must report the SRO-assigned identifier for the broker-dealer. 

Non-FINRA Member Firm Daily List

The Non-FINRA Member Firm Daily List is a list of all non-FINRA member firms who are US-registered broker-dealers as of the current trading day. FINRA will publish one file each day representing the list of non-FINRA Member Firms and their corresponding CRD number. The file will be available at approximately 7:15am EST. Please note that this list does not include non-member, non-US-registered broker-dealers that have an SRO-assigned identifier for purposes of accessing a FINRA facility. The Market Participant identifiers for these firms are available in existing sources.

The Non-FINRA Member Firm Daily List file is defined as follows: 

Field Name Maximum Data Length Definition
CRD 9 characters Central Registration Depository (CRD®) identifier of the US-registered broker-dealer that is not a member.
FIRM_NM 255 characters Firm Name

Link to Non-FINRA Member Firm List:

Non-FINRA Member Firm List File Retrieval Instructions:

The Reportable Non-Members List may be downloaded either by typing the URL in one of the supported browsers or via command line. Firms may use any standard transfer utility like CURL to download this list.

To retrieve the Reportable Non-Members List using the CURL for WINDOWS utility, enter the following commands from the windows command prompt: curl --output ReportableNonMembersList.txt