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ARTICLE · 12 AUGUST 2009

FINRA’s Trade Reporting Rule Amendments Become Effective

Cozen O'Connor
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On August 3, 2009, amendments to the Financial Industry Regulatory Authority’s (“FINRA”) trade reporting obligations for over-the-counter (“OTC”) equity transactions became effective.

United StatesFinance and Banking
Ralph De Martino
Ralph De Martino
Jessica Garvin
Jessica Garvin

On August 3, 2009, amendments to the Financial Industry Regulatory Authority's ("FINRA") trade reporting obligations for over-the-counter ("OTC") equity transactions became effective. The amendments, which the U.S. Securities and Exchange Commission (the "SEC") approved in November 20081, (i) replace the current market maker-based trade reporting structure with an "executing party" structure and (ii) require firms with the trade reporting obligations that are acting in a riskless principal or agency capacity on behalf of another member firm to submit non-tape reports to FINRA to identify such other firm as a party to the trade.

Trade Reporting Structure

The new "executing party" trade reporting structure applies to reporting trades to FINRA in National Market System securities, OTC equity securities, Direct Participation Program securities and PORTAL equity securities. Pursuant to the new structure, the trade reporting obligation falls (i) on the "executing

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