FINRA expects that, where possible, members will report both legs of a riskless principal transaction to the same FINRA Facility. The ATS OATS and Trade Reporting guidance applies irrespective of whether the execution occurs on an ATS. For purposes of this example, BD1 elects to report under Alternative #3 (i.e., the non-tape report shows BD1 and BD3 as the parties to the trade). Thus, for example, for a trade of 100.5 shares, the reported quantity would be 100. Under the four level or field modifier format, both modifiers can be accommodated on the transaction report and must be used if applicable. This guidance addresses the matching of orders from customers, other FINRA members and non-FINRA member broker-dealers, and applies where the executing firm uses multiple MPIDs, irrespective of whether the execution occurs on an ATS. Q306.2: Member BD1 satisfies a customer's order to buy with inventory from BD1's proprietary account. Transactions in Restricted Equity Securities effected pursuant to SEC Rule 144A and executed between 8:00 p.m. and midnight must be reported the following business day (T+1) by 8:00 p.m. See Rule 6622(a)(3); see also Regulatory Notice 10-26 (May 2010). As stated in Trade Reporting Notice 9/17/2010, firms must not report trades in a manner designed to circumvent this important system and operational protocol. For technical or operational issues regarding the ADF or ORF, firms should contact FINRA Market Operations, and for technical or operational issues regarding the FINRA/NASDAQ TRF or FINRA/NYSE TRF, firms should contact NASDAQ or NYSE, respectively. A301.2: Yes. On this recording of a June 8, 2017, TRACE Phone-In Workshop, FINRA staff review relevant rules and regulations, and discuss testing and other relevant technical information related to the July 10 requirement for to begin reporting transactions in U.S. Treasury Securities to FINRA via the Trade Reporting and Compliance Engine (TRACE). Updated Opinions on Position Limits Under MiFID II Published by ESMA On February 7th, ESMA published seven opinions on position limits regarding commodity derivatives under MiFID II/MiFIR. Trades in NMS stocks and OTC Equity Securities executed during the hours the FINRA Facility to which the member is reporting is closed are not subject to 10-second reporting. Reports of trades executed on a non-business day (i.e., a weekend or holiday) and T+365 trades must be reported to the FINRA Facilities; they are no longer reported on “Paper Form T.” Such transactions are subject to regulatory transaction fees, but are not disseminated (or submitted to clearing) by the FINRA Facility. FINRA will evaluate the use of multiple MPIDs based upon the stated purpose(s) and system(s) for which the additional MPID(s) will be used.
BD2 represents the sell-side, and based on the interaction between the members, both members could reasonably maintain that they satisfy the definition of executing party. If the transaction is a "single event" and BD1 reports the trade as a single cross, BD1 must also submit the following non-tape reports to indicate that BD1 was acting on behalf of the other members: 1) BD1 (as agent) sells 100,000 shares to BD2