FINRA emphasizes the obligations of members to report securities transactions within
the required time period. All reportable transactions not reported within
the required time period shall be
marked late, and FINRA routinely monitors members' compliance with the
reporting requirement
s. If FINRA finds a pattern or practice of unexcused late reporting, that is, repeated reports of executions
submitted after the required time period without reasonable justification or exceptional circumstances, the member may be found to be in violation of
Rule 2010. Exceptional circumstances will be determined on a case-by-case basis and may include instances of system failure by a member or service bureau, or unusual market conditions, such as extreme volatility in a security, or in the market as a whole. Timely reporting of all transactions is necessary and appropriate for the fair and orderly operation of the marketplace, and FINRA will view noncompliance as a rule violation.