Consolidated Audit Trail (CAT)
Rule 613 under the Securities Exchange Act of 1934 requires FINRA and the national securities exchanges to jointly submit a National Market System (NMS) plan detailing how they would develop, implement and maintain a consolidated audit trail that collects and accurately identifies every order, cancellation, modification and trade execution for all exchange-listed equities and options across all U.S. markets. FINRA is working with the exchanges to develop an NMS plan that meets the requirements of Rule 613.
• FINRA Rule 6800 Series: Consolidated Audit Trail Compliance Rule
• Visit The Consolidated Audit Trail website (https://www.catnmsplan.com/) for more information
The National Securities Exchanges and FINRA Issue Joint Guidance on Clock Synchronization and Certification Requirements Under the CAT NMS Plan
On November 15, 2016, the SEC approved the National Market System Plan Governing the Consolidated Audit Trail (Plan). The Plan, as modified by an exemptive order issued by the SEC, includes synchronization and certification requirements with regard to business clocks that capture time in milliseconds.
• Finra Regulatory Notice 17-09 (March 2017): The National Securities Exchanges and FINRA Issue Joint Guidance on Clock Synchronization and Certification Requirements Under the CAT NMS Plan
FINRA Reminds Firms of Their Obligations Regarding Transactions in OTC Equity Securities Quoted Pursuant to a Submitted Form 211
In consultation with SEC staff, FINRA is reminding members of legal obligations that apply when initiating a quote in an over-the-counter (OTC) security in addition to filing a Form 211.
• FINRA Regulatory Notice 18-32 (September 24, 2018): FINRA Reminds Firms of their Obligations Regarding Transactions in OTC Equity Securities Quoted Pursuant to a Submitted Form 211
FINRA Reminds Firms of their Obligations when Effecting OTC Trades in Equity Securities on a Net Basis
FINRA is issuing this Notice to remind firms of their obligations under the FINRA trade reporting rules and other applicable FINRA and SEC rules when effecting over-the-counter (OTC) trades in equity securities on a “net” basis.
• FINRA Regulatory Notice 18-29 (September 12, 2018): FINRA Reminds Firms of their Obligations when Effecting OTC Trades in Equity Securities on a Net Basis
Reporting Transactions in U.S. Treasury Securities
Beginning July 10, 2017, FINRA member firms must begin reporting transactions in U.S. Treasury Securities to FINRA via TRACE. Regulatory Notice 16-39 describes the scope of the term “U.S. Treasury securities” for purposes of the new reporting requirement; the specific transactions in U.S. Treasury securities that are reportable and those that are exempt from the reporting requirement; and the information that must be reported to TRACE when reporting transactions in U.S. Treasury securities, including a new trade indicator and two new modifiers. FINRA is publishing technical specifications concurrently with this Notice, which are available on FINRA’s website. At this time, FINRA will not disseminate information on transactions in U.S. Treasury securities and will not charge transaction-level fees on transactions in U.S. Treasury securities reported to TRACE.
• FINRA Regulatory Notice 16-39 (October 2016): SEC Approves Rule Change to Require Reporting of Transactions in U.S. Treasury Securities to the Trade Reporting and Compliance Engine (TRACE).
Exemption from Trade Reporting Obligation for Certain Transactions on Alternative Trading Systems
On July 18, 2016, FINRA Rule 6732 (Exemption from Trade Reporting Obligation for Certain Transactions on an Alternative Trading System) became effective. Rule 6732 provides FINRA staff with the authority to grant a member alternative trading system (ATS) an exemption from the TRACE trade reporting obligations of Rule 6730 (Transaction Reporting) for transactions occurring on an ATS that meet specified conditions.
• FINRA Regulatory Notice 16-15 (April 2016): Exemption from Trade Reporting Obligation for Certain Transactions on Alternative Trading Systems