New Electronic Reporting Requirements for Large Options Positions Reports for Filing of Reportable Conventional Options Positions
GUIDANCE
Large Options Positions Reports
| SUGGESTED ROUTING |
KEY TOPICS |
Senior Management |
Options |
Executive Summary
As a result of enhancements to the Securities Industry Automation Corporation's (SIAC) Large Options Positions Reporting system, NASD is eliminating the manual reporting of Large Options Positions Reports (LOPRs). SIAC now has the capability to accept LOPRs for both conventional and standardized options1 positions on an electronic basis. As a result, all members will be required to file LOPRs through SIAC on an electronic basis. As of May 9, 2005, NASD will no longer accept manually filed LOPRs.
All members must successfully test with SIAC to ensure that they have the ability to report large options positions in the required format. Testing is currently available and must be completed by May 6, 2005.
Questions/Further Information
Questions concerning these new reporting provisions can be directed to Mark G. Nolan, Team Leader, Market Regulation Department, at (240) 386-6174; or Susan Tibbs, Deputy Director, Market Regulation Department, at (240) 386-5082.
Background and Discussion
NASD Rule 2860(b)(5) requires member firms to file, or cause to be filed, reports for each account2 that has an aggregate position of 200 or more options contracts (whether long or short) on the same side of the market covering the same underlying security or index. These reports are referred to as LOPRs. With respect to listed options (also known as standardized options), a member firm currently may comply with this requirement by filing, or ensuring that another firm files on its behalf, reports to SIAC, or by manually filing a LOPR form by faxing it to NASD. With respect to over-the-counter options (also known as conventional options), a member firm currently must manually file a LOPR form because SIAC has not up to this point accepted electronic reports with respect to conventional option positions.
To enable NASD to enhance the efficiency of options surveillance, SIAC has developed the capability to accept reporting of conventional options positions on an electronic basis. The electronic reporting to SIAC of such options positions is now available. Beginning May 9, 2005, NASD will require all members to report all large options positions (for both conventional and standardized options) required to be reported under NASD Rule 2860 through SIAC on an electronic basis. NASD will continue to accept manually filed LOPRs only until May 6, 2005.
Current Requirements
All NASD Members
NASD Rule 2860 currently requires NASD member firms to file LOPRs in a manner prescribed by NASD. All NASD members currently must transmit LOPRs in conventional options via facsimile to NASD.
NASD/Options Exchange Members
NASD members that are also members of an options exchange on which the option is listed and traded may currently comply with this obligation by transmitting LOPRs in electronic form to SIAC.
Electronic Filing of LOPRs
NASD is enhancing LOPR reporting by requiring the electronic reporting of conventional options positions, which, up to this point, have only been reported to NASD via facsimile. This requirement will become effective on May 9, 2005. As a result, commencing on this date, NASD will no longer support or otherwise permit the filing of any LOPRs (whether such reports cover standardized or conventional options) via facsimile. Under the new requirements, position reports in conventional and standardized options must be reported to SIAC on an electronic basis using designated record types. Member firms will be able to add conventional option reports to their existing LOPR transmissions for standardized options or send them to SIAC as a separate file. The record layout of the new options positions report is set forth in Attachment A.
LOPRs should be transmitted to SIAC no later than the close of business on the next business day following the day on which the transaction or transactions requiring the filing of such report occurred.3
NASD has also determined to enhance LOPR reporting to support member firm transmissions to SIAC of hedge instrument positions involving standardized and conventional options.4 The record layout of the new report for hedge instrument positions is also set forth in Attachment A.
Testing
Prior to being approved to submit production data to SIAC, each submitting organization must conduct a successful test with SIAC. The test will verify connectivity and check the format and content of a test file.
In order to establish connectivity to SIAC and/or conduct a test, please contact SIAC's Client Activation Group at (212) 383-5401 and identify your request by mentioning Sysid 28044.
All members must successfully test with SIAC in order to be in compliance with these new provisions by the effective date of May 9, 2005.
1 NASD would like to remind its members that LOPR filings to NASD pursuant to NASD Rule 2860(b)(5) should be made with respect to reportable positions in options only and not in any other derivative security. Members, and those entities filing on behalf of NASD members, must not report positions in other financial instruments in a LOPR filing to NASD, aside from those instruments being reported as hedges against reportable options positions.
2 Accounts for which reports are required pursuant to NASD Rule 2860(b)(5)(A)(i)a include accounts in which the member has an interest, each account of a partner, officer, director, or employee of such member, and of each customer, non-member broker, or non-member dealer. As such, if a member enters into a transaction with a customer creating a reportable position for both the member and the customer, then NASD Rules require that a LOPR reporting each position be submitted for both the customer and the member.
3See NASD Conduct Rule 2860(b)(5)(A)(ii).
4 NASD previously issued guidance regarding hedge instrument position reporting in NTM 97-56.
ATTACHMENT A
File Description
The ISG Large Options Positions Reporting System (LOPR) utilizes the input file described in this document. The file consists of the following structure:
Datatrak Header Record Identifies the file as a LOPR input file. Must be the first record in the file.
Account Description and Position Records For each account/trade date, up to five records may be present that provide the name on the account (Record Types 1-5). Following the Account Name records will be any number of position records for the account. There are six types of Position Records. Any or all types may be reported for a given account.
Listed Option Positions (Record Type 6).
Hedge Instrument Positions on Listed Options (Record Type 7).
Currency and Stock Index Warrant Positions (Record Type 8).
OTC Option Positions (Record Types A and B).
Hedge Instrument Positions on OTC Options (Record Type C).
Datatrak Trailer Record Must be the last record in the file.
The first 34 characters in all records (except Datatrak Header and Trailer) consist of a key that must be the same in all records for an account for a given trade date. Positions for multiple trade dates may be reported in a single file.
All alphanumeric (X) fields must be left justified and space filled. All numeric (9) fields must be right justified and zero filled.
Establishing Connectivity To SIAC
Organizations that do not already have connectivity to SIAC's Shared Data Center and its Datatrak input subsystem, must contact SIAC's Client Activation Group at (212) 383-5401. Please identify your request by mentioning Datatrak Sysid 28044. Various connectivity options will be presented to you.
If you already maintain connectivity to SIAC, you may use the Datatrak Originator and Sub-Originator you use in other file transmissions.
Testing Requirements
Prior to being approved to submit production data to SIAC, each submitting organization must conduct a successful test with SIAC. The test will verify connectivity and check the format and content of a test file. Please contact SIAC's Client Activation Group at (212) 383-5401 and once again identify your request by mentioning Datatrak Sysid 28044. They will also assign Datatrak Originator and Sub-Originator codes that must be included as part of the Datatrak header and trailer records.
Datatrak Header Record
The Datatrak header record must be the first record in the file.
| Position | Field Name | Description | Format | Value |
| 1-16 | System ID | Identifies an ISG Large Options Positions File. | X(16) | HDR.S28044.E00.C |
| 17-20 | Originator | Identifies organization sending the file. | X(4) | Assigned by SIAC; please call (212) 383-5401. |
| 21-22 | Filler | X(2) | .S | |
| 23-26 | Sub-Originator | Identifies organization sending the file. | X(4) | Assigned by SIAC; please call (212) 383-5401. |
| 27-27 | Filler | X(1) | Space. | |
| 28-33 | Date | Date of file submission. | X(6) | MMDDYY |
| 34-34 | Filler | X(1) | Space. | |
| 35-59 | Description | Textual identification of the file. | X(25) | ISG OPT. LARGE POS. |
| 60-80 | Filler | X(21) | Space. |
Account Name RecordsRecord Types 1-5
Up to five records (Record Types 1-5) are used to provide the name and address on the account.
| Position | Field Name | Description | Format | Value |
| 1 | Firm Type | Identifies the type of firm submitting the report. | X(1) | O = Firm that is only NASD member. L = Member of an option exchange. |
| 2-7 | Trade Date | Position effective date. | 9(6) | MMDDYY |
| 8-11 | Firm ID | Reporting firm ID. | X(4) | OCC clearing number if OCC clearing firm or listed options market assigned number. If only NASD member, alpha identifier. |
| 12-15 | Branch | Firm branch code. | X(4 | |
| 16-24 | Account Number | Account number. | X(9) | |
| 25-33 | Social Security Number or Tax ID |
Social Security Number or Tax ID depending on the Indicator field. | X(9) | If Social Security/Tax ID Indicator is "F" or "N," this field could be zero. |
| 34-34 | Social Security Number or Tax ID Indicator |
Indicates whether the above field is a Social Security Number or a Tax ID. | X(1) | S = Social Security Number. T = Tax ID. F = Foreign. N = Not available. |
| 35-35 | Record Type | Identifies account name records. | X(1) | Values = 1-5. |
| Record Type 1 must be present. Record Types 2-5 are optional, but must appear in numerical order. | ||||
| 36-65 | Account Name/Address | Name/Address on the account. | X(30) | The last line of the address should include the City, State, and ZIP or Country Code.1 |
| 66-80 | Filler | X(15) | Spaces. |
Listed Options Positions RecordRecord Type 6
These records must appear after the account name records (Record Types 1-5) for a given account/trade date.
| Position | Field Name | Description | Format | Value |
| 1 | Firm Type | Identifies the type of firm submitting the report. | X(1) | O = Firm that is only NASD member. L = Member of an option exchange. |
| 2-7 | Trade Date | Position effective date. | 9(6) | MMDDYY |
| 8-11 | Firm ID | Reporting firm ID. | X(4) | OCC clearing number if OCC clearing firm or listed options market assigned number. If only NASD member, alpha identifier. |
| 12-15 | Branch | Firm branch code. | X(4) | |
| 16-24 | Account Number | Account number. | X(9) | |
| 25-33 | Social Security Number or Tax ID |
Social Security Number or Tax ID depending on the Indicator field. | X(9) | If Social Security/Tax ID Indicator is "F" or "N," this field could be zero. |
| 34-34 | Social Security Number or Tax ID Indicator | Indicates whether the above field is a Social Security Number or a Tax ID. | X(1) | S = Social Security Number. T = Tax ID. F = Foreign. N = Not available. |
| 35-35 | Record Type | Identifies a listed option position report. | X(1) | 6 |
| 36-41 | Symbol | Option symbol. | X(6) | Use the 3-6 character option symbol. |
| 42-44 | Month | Expiration month. | X(3) | JAN, FEB, MAR, APR, MAY, JUN, JUL, AUG, SEP, OCT, NOV, DEC. |
| 45-46 | Year | Expiration year. | 9(2) | Last 2 digits of the year. |
| 47-47 | Put/Call | Put/Call indicator. | X(1) | P = Put. C = Call. |
| 48-59 | Strike Price | Strike price. | 9(6) V9(6) |
|
| 60-66 | Long Quantity | Long position. | 9(7) | If no position, set to zero. |
| 67-73 | Short Covered | Short covered position. | 9(7) | If no position, set to zero. |
| 74-80 | Short Uncovered | Short Uncovered | 9(7) | If no position, set to zero. |
Hedge Instrument Positions on Listed OptionsRecord Type 7
These records must appear after account name records (Record Types 1-5) and any listed option position records (Record Type 6) for a given account/trade date.
| Position | Field Name | Description | Format | Value |
| 1 | Firm Type | Identifies the type of firm submitting the report. | X(1) | O = Firm that is only NASD member. L = Member of an option exchange. |
| 2-7 | Trade Date | Closing position effective date. | 9(6) | MMDDYY |
| 8-11 | Firm ID | Reporting firm ID. | X(4) | OCC clearing number if OCC clearing firm or listed options market assigned number. If only NASD member, alpha identifier. |
| 12-15 | Branch | Firm branch code. | X(4) | |
| 16-24 | Account Number | Account number. | X(9) | |
| 25-33 | Social Security Number or Tax ID | Social Security Number or Tax ID depending on the Indicator field. | X(9) | If Social Security/Tax ID Indicator is "F" or "N," this field could be zero. |
| 34-34 | Social Security Number or Tax ID Indicator | Indicates whether the above field is a Social Security Number or a Tax ID. | X(1) | S = Social Security Number. T = Tax ID. F = Foreign. N = Not available. |
| 35-35 | Record Type | Identifies a hedge instrument position report on listed options. |
X(1) | 7 |
| 36-45 | Option Symbol | Option symbol. | X(10) | Use the 3-6 character symbol of the option that is being hedged. |
| 46-55 | Hedge Instrument Symbol | Hedge instrument symbol. | X(10) | |
| 56-59 | Filler | X(4) | Spaces. | |
| 60-68 | Long | Long position. | 9(9) | |
| 69-77 | Short | Short position. | 9(9) | |
| 78-80 | Filler | X(3) | Spaces. |
Positions on Currency and Stock Index WarrantsRecord Type 8
These records must appear after account name records (Record Types 1-5) and any listed option position records (Record Type 6) or hedge instrument position records (Record Type 7) for a given account/trade date.
| Position | Field Name | Description | Format | Value |
| 1 | Firm Type | Identifies the type of firm submitting the report. | X(1) | O = Firm that is only NASD member. L = Member of an option exchange. |
| 2-7 | Trade Date | Closing position effective date. | 9(6) | MMDDYY |
| 8-11 | Firm ID | Reporting firm ID. | X(4) | OCC clearing number if OCC clearing firm or listed options market assigned number. If only NASD member, alpha identifier. |
| 12-15 | Branch | Firm branch code. | X(4) | |
| 16-24 | Account Number | Account number. | X(9) | |
| 25-33 | Social Security Number or Tax ID |
Social Security Number or Tax ID depending on the Indicator field. | X(9) | If Social Security/Tax ID Indicator is "F" or "N," this field could be zero. |
| 34-34 | Social Security Number or Tax ID Indicator | Indicates whether the above field is a Social Security Number or a Tax ID. | X(1) | S = Social Security Number. T = Tax ID. F = Foreign. N = Not available. |
| 35-35 | Record Type | Identifies a currency and stock index warrant position report. | X(1) | 8 |
| 36-45 | Warrant Symbol | Warrant symbol. | X(10) | |
| 46-59 | Filler | X(14) | Spaces. | |
| 60-68 | Long | Long position. | 9(9) | |
| 69-77 | Short | Short position. | 9(9) | |
| 78-80 | Filler | X(3) | Spaces. |
OTC Options PositionsRecord Type A
OTC options positions reports consist of a set of two records (Record Types A and B). They must appear consecutively after the account identification records (Record Types 1-5) and any other position reports (Record Types 6-8) for a given account/trade date.
| Position | Field Name | Description | Format | Value |
| 1 | Firm Type | Identifies the type of firm submitting the report. | X(1) | O = Firm that is only NASD member. L = Member of an option exchange. |
| 2-7 | Trade Date | Closing position effective date. | 9(6) | MMDDYY |
| 8-11 | Firm ID | Reporting firm ID. | X(4) | OCC clearing number if OCC clearing firm or listed options market assigned number. If only NASD member, alpha identifier. |
| 12-15 | Branch | Firm branch code. | X(4) | |
| 16-24 | Account Number | Account Number | X(9) | |
| 25-33 | Social Security Number or Tax ID |
Social Security Number or Tax ID depending on the Indicator field. | X(9) | If Social Security/Tax ID Indicator is "F" or "N," this field could be zero. |
| 34-34 | Social Security Number or Tax ID Indicator | Indicates whether the above field is a Social Security Number or a Tax ID. | X(1) | S = Social Security Number. T = Tax ID. F = Foreign. N = Not available. |
| 35-35 | Record Type | Identifies the first of two records of an OTC Options Positions report. | X(1) | A |
| 36-36 | Exercise Style | Indicates the exercise style. | X(1) | 1 = American; 2 = European. |
| 37-42 | Symbol | Option symbol. | X(6) | Same symbol as the underlying equity. |
| 43-45 | Filler | X(3) | Spaces. | |
| 46-51 | Expiration Date | Option expiration date. | 9(6) | MMDDYY |
| 52-52 | Put/Call | Put/Call indicator. | X(1) | P = Put C = Call |
| 53-64 | Strike Price | Strike price. | 9(6) V9(6) |
|
| 65-71 | Multiplier | Shares per contract. | 9(7) | |
| 72-80 | Filler | X(9) | Spaces. |
OTC Options PositionsRecord Type B
| Position | Field Name | Description | Format | Value |
| 1 | Firm Type | Identifies the type of firm submitting the report. | X(1) | O = Firm that is only NASD member. L = Member of an option exchange. |
| 2-7 | Trade Date | Closing position effective date. | 9(6) | MMDDYY |
| 8-11 | Firm ID | Reporting firm ID. | X(4) | OCC clearing # if OCC clearing firm or listed options market assigned number. If only NASD member, alpha identifier. |
| 12-15 | Branch | Firm branch code. | X(4) | |
| 16-24 | Account Number | Account Number | X(9) | |
| 25-33 | Social Security Number or Tax ID |
Social Security Number or Tax ID depending on the Indicator field. | X(9) | If Social Security/Tax ID Indicator is "F" or "N," |
| 34-34 | SSN/Tax ID Indicator | Indicates whether the above field is a Social Security Number or a Tax ID. | X(1) | S = Social Security Number; T = Tax ID; F = Foreign; N = Not available. |
| 35-35 | Record Type | Identifies the second of two records of an OTC Options Positions report. | X(1) | B |
| 36-36 | Foreign/Regional Indicator | Indicates if option is on a foreign security or a domestic security that only trades on a regional. | X(1) | F = Option on a foreign stock. R = Option on a regional stock. Space = Option on a stock listed on the Amex, NASDAQ, or NYSE. |
| 37-37 | OTC Index Option | Reserved for future use. | X(1) | Space. |
| 38-44 | Final Long Quantity | Final long position. | 9(7) | If no position, set to zero. |
| 45-51 | Final Short Covered | Final short covered position. | 9(7) | If no position, set to zero. |
| 52-58 | Final Short Uncovered |
Final short uncovered position. | 9(7) | If no position, set to zero. |
| 59-65 | Intra-day Long | Intra-day long position. | 9(7) | If no position, set to zero. |
| 66-72 | Intra-day Short Covered | Intra-day short covered position. | 9(7) | If no position, set to zero. |
| 73-79 | Intra-day Short Uncovered |
Intra-day short uncovered position. | 9(7) | If no position, set to zero. |
| 80-80 | Hedge Indicator | OTC position is hedging a listed option position or vice versa. |
X(1) | L = Position is a hedge. Space = Position is not a hedge. |
Hedge Instrument Position Report on OTC OptionsRecord Type C
These records must appear after the account identification records (Record Types 1-5) and any other position reports (Record Types 6-8, A, B) for a given account/trade date.
| Position | Field Name | Description | Format | Value |
| 1 | Firm Type | Identifies the type of firm submitting the report. | X(1) | O = Firm that is only NASD member. L = Member of an option exchange. |
| 2-7 | Trade Date | Closing position effective date. | 9(6) | MMDDYY |
| 8-11 | Firm ID | Reporting firm ID. | X(4) | OCC clearing number if OCC clearing firm or listed options market assigned number. If only NASD member, alpha identifier. |
| 12-15 | Branch | Firm branch code. | X(4) | |
| 16-24 | Account Number | Account number. | X(9) | |
| 25-33 | Social Security Number or Tax ID | Social Security or Tax ID depending on the Indicator field. | X(9) | If Social Security/Tax ID Indicator is "F" or "N," this field could be zero. |
| 34-34 | Social Security Number or Tax ID Indicator | Indicates whether the above field is a Social Security Number or a Tax ID. | X(1) | S = Social Security Number. T = Tax ID. F = Foreign. N = Not available. |
| 35-35 | Record Type | Identifies a hedge instrument position report on OTC options. |
X(1) | C |
| 36-36 | Exercise Style | Indicates the exercise style. | X(1) | 1 = American style. 2 = European style. |
| 37-42 | Symbol | Option symbol. | X(6) |
Symbol of the option that is being hedged, should use the same symbol as the underlying entity. |
| 43-45 | Filler | X(3) | Spaces. | |
| 46-55 | Hedge Instrument Symbol | Hedge instrument symbol. | X(10) | |
| 56-59 | Filler | X(4) | Spaces. | |
| 60-68 | Long | Long position. | 9(9) | Right justified, zero filled. |
| 69-77 | Short | Short position. | 9(9) | Right justified, zero filled. |
| 78-78 | Foreign/Regional Indicator | Indicates if option is on a foreign security or a domestic security that only trades on a regional. | X(1) | F = Option on a foreign stock. R = Option on a regional stock. Space = Option on a stock listed on the Amex, NASDAQ, or NYSE. |
| 79-80 | Filler | X(2) | Spaces. |
Datatrak Trailer Record
This record must be the last one in the file.
| Position | Field Name | Description | Format | Value |
| 1-16 | Trailer ID | Identifies the Trailer Record. | X(16) | END.S28044.E00.C |
| 17-20 | Originator | Identifies organization sending the file. | X(4) | Same as Header Record. |
| 21-22 | Filler | X(2) | .S | |
| 23-26 | Sub-Originator | Identifies organization sending the file. | X(4) | Same as Header Record. |
| 27-80 | Filler | X(54) | Spaces. |
1 Separate Account Name/Address records should be provided to represent each line of the full account name and address. For example, to report Account information for the following account: James Q Public, c/o Fairfax Investment Group, 1500 Broadway, New York, NY 10036, four Account Name/Address records must be submitted, with Account Name/Address fields populated as follows:
Record Type 1 Account Name/Address = James Q Public'
Record Type 2 Account Name/Address = c/o Fairfax Investment Group'
Record Type 3 Account Name/Address = 1500 Broadway'
Record Type 4 Account Name/Address = New York, NY 10036'
Information reported in all other fields must be the same for each of the four records.