On Monday, January 25, 2021, from 9:30 a.m. ET until approximately 9:57 a.m. ET, the FINRA/Nasdaq TRF Carteret experienced a networking issue that resulted in trades in Nasdaq-listed symbols being disseminated to the SIP in an untimely manner. Reporting by clients to the FINRA/Nasdaq TRF Carteret was unaffected. There are no actions that need to be taken by clients as a result of this
Term
Description
Exceptions Periods
Date of all listed options position, as reported.
Total Number of Exceptions
Total number of issues reported during the period.
Large Options Positions Reported (LOPR) - Listed Detail Data
Term
Description
Position Date
The position date
FINRA has updated its Guidance on OATS Exchange Route Matching to reflect changes necessary for firms to successfully match OATS routes to the related order on the Members Equity Exchange. Specifically, the update applies to Binary Users accessing the Members Equity Exchange and how to populate the Connection ID in OATS to ensure proper matching. If
Firms have shared the following ways they have used prior FINRA publications, such as Exam Findings Reports and Priorities Letters (collectively, Reports), to enhance their compliance programs. We encourage firms to consider these practices, if relevant to their business model, and continue to provide feedback on how they use FINRA publications.
Assessment of Applicability – Performed a
Regulatory Obligations and Related Considerations
Regulatory Obligations
Exchange Act Rule 15c3-3 (Customer Protection Rule) imposes certain requirements on firms that are designed to protect customer funds and securities. Firms are obligated to maintain custody of customer securities and safeguard customer cash by segregating these assets from the firm’s proprietary business activities, and
Net Capital
Liquidity Management
Credit Risk Management
Segregation of Assets and Customer Protection
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Vendor Display Rule
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Net Capital
Rule 603 of Regulation NMS (Vendor Display Rule) generally requires broker-dealers to provide a consolidated display of market data for NMS stocks for which they provide quotation information to customers.
Exchange Act Rule 15c3-5 (Market Access Rule) requires broker-dealers with market access or that provide market access to their customers to “appropriately control the risks associated with market access so as not to jeopardize their own financial condition, that of other market participants, the integrity of trading on the securities markets, and the stability of the financial system.”
Regulatory Obligations and Related Considerations
Regulatory Obligations
Exchange Act Rule 13h-1 (Large Trader Rule) requires “large traders” to identify themselves as such to the SEC, disclose to other firms their large trader status and, in certain situations, comply with certain filing, recordkeeping and reporting requirements. These requirements help the SEC identify large traders and
FINRA Rule 5310 (Best Execution and Interpositioning) requires that, in any transaction for or with a customer or a customer of another broker-dealer, a member and persons associated with a member shall use reasonable diligence to ascertain the best market for the subject security, and buy or sell in such market so that the resultant price to the customer is as favorable as possible under prevailing market conditions.
