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ARTICLE · 22 JUNE 2017

FINRA Sets Implementation Date For New TRACE Reporting Modifiers

Hogan Lovells Cadwalader
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FINRA filed a proposed rule change relating to the implementation date of rules requiring firms to use two new trade modifiers when reporting transactions in U.S. Treasury Securities to FINRA via the TRACE.

United StatesFinance and Banking

FINRA filed a proposed rule change relating to the implementation date of rules requiring firms to use two new trade modifiers when reporting transactions in U.S. Treasury Securities to FINRA via the Transaction Reporting and Compliance Engine ("TRACE"). The proposed implementation date would be February 5, 2018.

As previously covered, firms are required to use the new modifiers as follows:

  • a ".B" modifier, if the transaction being reported is part of a series in which at least one transaction involves a futures contract; and
  • an ".S" modifier, if the transaction being reported is part of a series of transactions and may not be priced based on the current market.

FINRA filed the rule change for immediate effectiveness. Firms may use the modifiers as soon as the new TRACE reporting requirements become effective on July 10, 2017. FINRA's proposed implementation date of February 5, 2018 gives firms ample time to prepare systems for compliance with the new reporting requirement.

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