Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Notice of Filing of a Proposed Rule Change To Amend FINRA Rules 7410 (Definitions) and 7440 (Recording of Order Information), 9545-9550 [2016-03941]
Download as PDF
Federal Register / Vol. 81, No. 37 / Thursday, February 25, 2016 / Notices
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
BATS–2016–08 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Brent J. Fields, Secretary, Securities
and Exchange Commission, 100 F Street
NE., Washington, DC 20549–1090.
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All submissions should refer to File
Number SR–BATS–2016–08. This file
number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549 on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of such
filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–BATS–
2016–08, and should be submitted on or
before March 17, 2016.
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–77180; File No. SR–FINRA–
2016–006]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Notice of Filing of a
Proposed Rule Change To Amend
FINRA Rules 7410 (Definitions) and
7440 (Recording of Order Information)
February 19, 2016.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that on February
11, 2016, Financial Industry Regulatory
Authority, Inc. (‘‘FINRA’’) filed with the
Securities and Exchange Commission
(‘‘SEC’’ or ‘‘Commission’’) the proposed
rule change as described in Items I, II,
and III below, which Items have been
prepared by FINRA. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
FINRA is proposing to amend FINRA
Rules 7410 and 7440 to require FINRA
members to identify on their Order
Audit Trail System (‘‘OATS’’) reports
the identity of certain broker-dealers
that are not FINRA members when the
member has received an order from
such a broker-dealer.
Below is the text of the proposed rule
change. Proposed new language is in
italics; proposed deletions are in
brackets.
*
*
*
*
*
7000. CLEARING, TRANSACTION
AND ORDER DATA REQUIREMENTS,
AND FACILITY CHARGES
*
*
*
*
*
7400. ORDER AUDIT TRAIL SYSTEM
*
*
*
*
*
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.17
Brent J. Fields,
Secretary.
7410. Definitions
(a) through (o) No Change.
(p) ‘‘SRO-assigned identifier’’ shall
mean a unique identifier assigned to a
broker or dealer by a national securities
exchange or national securities
association for use by such broker or
dealer when accessing the exchange or
a facility of the association.
[FR Doc. 2016–03943 Filed 2–24–16; 8:45 am]
*
BILLING CODE 8011–01–P
7440. Recording of Order Information
(a) No Change.
*
1 15
17 17
CFR 200.30–3(a)(12).
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*
*
*
U.S.C. 78s(b)(1).
CFR 240.19b–4.
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9545
(b) Order Origination and Receipt
Unless otherwise indicated, the
following order information must be
recorded under this Rule when an order
is received or originated. For purposes
of this Rule, the order origination or
receipt time is the time the order is
received from the customer.
(1) through (17) No Change.
(18) the type of account, i.e., retail,
wholesale, employee, proprietary, or
any other type of account designated by
FINRA, for which the order is
submitted; [and]
(19) when the Reporting Member
receives an order from a U.S.-registered
broker-dealer that is not a member, or
from a non-U.S.-registered broker-dealer
that is not a member but has received
an SRO-assigned identifier for purposes
of accessing a FINRA facility pursuant
to Rule 7220A or 7320, identification of
such broker-dealer by providing an
SRO-assigned identifier assigned to the
broker-dealer or the number assigned to
the broker-dealer in the Central
Registration Depository system; and
(20) if the member is relying on the
exception provided in Rule 5320.02
with respect to the order, the unique
identification of any appropriate
information barriers in place at the
department within the member where
the order was received or originated.
(c) through (d) No Change.
*
*
*
*
*
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission,
FINRA included statements concerning
the purpose of and basis for the
proposed rule change and discussed any
comments it received on the proposed
rule change. The text of these statements
may be examined at the places specified
in Item IV below. FINRA has prepared
summaries, set forth in sections A, B,
and C below, of the most significant
aspects of such statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
FINRA is proposing an amendment to
Rule 7440 of the OATS rules to require
FINRA members subject to the OATS
rules (‘‘Reporting Members’’) to
specifically identify two types of nonFINRA-member broker-dealers (‘‘NonMember Firms’’) as part of the OATS
report when they receive orders from
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these firms.3 Under the proposed rule
change, Reporting Members receiving an
order from either a U.S.-registered
broker-dealer that is not a FINRA
member or a broker-dealer that is not
registered in the U.S. but has received
an SRO-assigned identifier 4 in order to
access certain FINRA trade reporting
facilities (each a ‘‘Reportable NonMember’’) must identify the brokerdealer when reporting receipt of the
order to OATS.5 Pursuant to the
proposed rule change, and as described
below, Reporting Members receiving an
order from or routing an order to a NonMember Firm would therefore report
one of the following: The Non-Member
Firm’s Central Registration Depository
(‘‘CRD®’’) number; an SRO-assigned
identifier assigned to the Non-Member
Firm; or, for a Non-Member Firm that
does not have a CRD number or SROassigned identifier (e.g., a foreign
broker-dealer), a value indicating that
the Non-Member Firm has no CRD
number or SRO-assigned identifier.
Reporting this information will allow
FINRA to obtain the identity of
Reportable Non-Members directly from
the OATS report.
A Reporting Member receiving an
order from a Reportable Non-Member
would include on its OATS report either
the SRO-assigned identifier (e.g., a
market participant identifier (‘‘MPID’’)
assigned by a national securities
exchange) or the Reportable NonMember’s CRD number.6 The proposed
rule change does not mandate which
identifier Reporting Members must use;
thus, Reporting Members may use either
an existing SRO-assigned identifier or a
CRD number on their OATS reports to
identify the Reportable Non-Member. If
a Reportable Non-Member does not have
an SRO-assigned identifier that is
3 FINRA Rule 7410(o) defines a Reporting
Member as ‘‘a member that receives or originates an
order and has an obligation to report information
under Rules 7440 and 7450.’’ The rule also contains
exceptions from the rule. See FINRA Rule
7410(o)(1) and (2).
4 FINRA is proposing to define an ‘‘SRO-assigned
identifier’’ in Rule 7410 as ‘‘a unique identifier
assigned to a broker or dealer by a national
securities exchange or national securities
association for use by such broker or dealer when
accessing the exchange or a facility of the
association.’’ For purposes of the definition, the
identifier is ‘‘unique’’ provided the identifier
assigned by the exchange or association is used to
identify only a single broker-dealer.
5 Certain broker-dealers registered in Canada, but
not in the U.S., have SRO-assigned identifiers so
that they can access FINRA trade reporting facilities
pursuant to FINRA Rule 7220A or 7320.
6 To register as a broker-dealer and have a CRD
number, firms are required to file a Form BD with
CRD. See 17 CFR 240.15b1–1(b). Consequently, all
U.S.-registered broker-dealers have a CRD number.
Currently, all U.S.-registered broker-dealers also
have at least one SRO-assigned identifier that is
available to FINRA.
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available to FINRA, the Reporting
Member receiving the order would be
required to report the CRD number of
the Reportable Non-Member.7 Similarly,
for a non-U.S.-registered broker-dealer
that has an SRO-assigned identifier in
order to access a FINRA trade reporting
facility pursuant to Rule 7220A or 7320
but does not have a CRD number, the
Reporting Member receiving the order
would be required to report the SROassigned identifier for the broker-dealer.
FINRA is filing the proposed rule
change to enhance its market
surveillance efforts, both under its own
SRO license and pursuant to its
Regulatory Service Agreements
(‘‘RSAs’’) with multiple national
securities exchanges, by being able to
identify more Non-Member Firm trading
activity across exchanges and in the
over-the-counter market through trades
that are reported to a FINRA trade
reporting facility.8 Through OATS,
FINRA is currently able to identify in
detail the order and trading activity of
FINRA member broker-dealers across
market centers. Using data provided by
the exchanges as well as CRD numbers,
FINRA is also able to identify in detail
the trading activities of Non-Member
Firms and aggregate these firms’
activities across RSA client exchanges.9
Although Reporting Members report
orders they receive from, or route to,
Non-Member Firms, these reports do not
always contain the identity of the NonMember Firm from whom the order was
received, or to whom it was routed.10
7 Because non-U.S. broker-dealers generally do
not have SRO-assigned identifiers or CRD numbers,
the proposed rule change would not require specific
identification of non-U.S. broker-dealers when
those firms do not have SRO-assigned identifiers or
CRD numbers. In these cases, FINRA intends to
permit a value whereby the Reporting Member
would indicate the order was received from a nonU.S. broker-dealer without a CRD number or SROassigned identifier.
8 FINRA obtains exchange data pursuant to RSAs
it has signed with certain client exchanges. Under
the current RSAs with national securities
exchanges, FINRA conducts comprehensive
surveillance across more than 99% of the market for
U.S. listed equities by share and trade volume.
9 This is accomplished by using exchangeassigned identifiers that are mapped to the firm’s
CRD number. FINRA has access to all SRO-assigned
equity identifiers with the exception of those
assigned by the Chicago Stock Exchange. Under the
proposed rule change, FINRA would thus be able
to use any of these SRO-assigned identifiers or a
CRD number to obtain the identity of the NonMember Firm on OATS reports. A FINRA member
that provides sponsored access to a Non-Member
Firm has an OATS reporting obligation for each
order sent to a national securities exchange
pursuant to any such agreement. In this scenario,
the FINRA member must report a New Order and
a Route Report to the applicable exchange reflecting
that the order was received from a Non-Member
Firm. See OATS FAQ C77.
10 Although some Reporting Members voluntarily
provide the MPID of a Non-Member Firm if one
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FINRA cannot, therefore, currently
identify in detail Non-Member Firm
activity in the over-the-counter market,
or Non-Member Firm sponsored access
activity, since Reporting Members are
not required to report to OATS the
identity of Non-Member Firms.
Consequently, FINRA is not able to
consistently identify Non-Member Firm
activity and does not have a complete
view of such activities across all
exchanges and over-the-counter market
centers. As the Commission recently
noted when it proposed amendments to
SEA Rule 15b9–1,11 ‘‘FINRA’s ability to
perform comprehensive market
surveillance, especially for violations of
Commission rules, as well as its ability
to understand and reconstruct activity
in the off-exchange market generally, is
limited because [Non-Member Firms]
are not consistently identified in trade
reports to the TRFs or the ADF, and
their order activity is not captured by
OATS.’’ 12
In addition to amending Rule 7440 to
require the identification of Reportable
Non-Members from which an order is
received, FINRA is also planning to
update the OATS Reporting Technical
Specifications to require that OATS
reports specifically identify a Reportable
Non-Member to which an order is
routed. Rule 7440(c)(6)(I) requires that,
for orders routed from a member to a
non-FINRA-member, including both
non-FINRA-member broker-dealers and
national securities exchanges, the
identity of the non-FINRA member to
which the order was routed be reported.
Although the OATS Reporting
Technical Specifications currently
require that OATS reports include a
specific identifier for each national
securities exchange to which an order is
routed, only a generic identifier for NonMember Firms is required.13
Consequently, the identity of the
specific Non-Member Firm to which an
order is routed is not required under the
current OATS Reporting Technical
Specifications. To address this gap and
to conform the reporting of orders
received from and orders routed to NonMember Firms, in addition to the
proposed rule change, FINRA intends to
update the OATS Reporting Technical
Specifications to require that Reporting
Members provide either an SROassigned identifier or CRD number
exists, the OATS rules do not require that the
identity of the Non-Member Firm be reported.
11 17 CFR 240.15b9–1.
12 See Securities Exchange Act Release No. 74581
(March 25, 2015), 80 FR 18036, 18043 (April 2,
2015).
13 See OATS Reporting Technical Specifications,
at 4–4, and A–4 to A–5 (October 12, 2015 ed.).
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when routing an order to a Reportable
Non-Member.14
The proposed rule change, along with
the changes to the OATS Reporting
Technical Specifications, will
significantly improve FINRA’s ability to
support cross-market surveillance and
monitor over-the-counter trading
activity. Reporting Members receive a
substantial amount of order flow from
Non-Member Firms, particularly in
connection with alternative trading
system (‘‘ATS’’) activity, and this
proposed rule change will enable
FINRA to identify the activities of
Reportable Non-Members, thereby
increasing its cross-market surveillance
capabilities.15
FINRA notes that although the data
required by the proposed rule change
may ultimately be captured as part of
the Consolidated Audit Trail (‘‘CAT’’),
the implementation of the CAT is likely
several years away, as the national
market system plan filed by the SROs
still must be published by the
Commission for public notice and
comment, approved by the SEC, and, if
approved, ultimately implemented
pursuant to a multi-year timeline.16
FINRA strongly believes that gaps in
OATS data must be addressed in the
near-term, after weighing the burdens to
firms and the necessity of the change, to
ensure an effective audit trail. FINRA
believes the specific identification of
Reportable Non-Members is critical to
enhance FINRA’s cross-market
surveillance and monitoring of the overthe-counter market and believes these
changes to the OATS requirements
should not be delayed due to the
14 As noted above, in the case of a non-U.S.
broker-dealer that does not have a CRD number or
an SRO-assigned identifier, FINRA will provide an
indicator for ‘‘non-U.S. broker-dealer’’ for use in the
destination code field (for routes to a non-member
broker-dealer) and as a member type code (for
orders received from a non-member broker-dealer).
15 For example, in the fourth quarter of 2014, over
33% of orders reported to OATS were reported as
being received from a Non-Member Firm. Of
particular note, over 45% of ATS orders were
received from a Non-Member Firm. In addition,
during that quarter approximately 13% of
sponsored access orders were received from a NonMember Firm.
16 SEC Rule 613, which sets forth the
requirements for the CAT, does not require all
broker-dealers to report order information to the
CAT until three years after the CAT plan is
approved. See 17 CFR 242.613(a)(vi). The SROs
charged with submitting the CAT plan filed an
initial plan with the Commission on September 30,
2014, an amended and restated plan on February
27, 2015, and further amendments on December 23,
2015; however, the Commission has not yet
published the CAT plan in the Federal Register for
public comment. Pursuant to the plan submitted by
the SROs, once the CAT is fully implemented,
FINRA intends to sunset the OATS rules.
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potential future implementation of the
CAT.17
In addition to the CAT, the proposed
rule change could also be affected by
any amendments to SEA Rule 15b9–1.18
Section 15(b)(8) of the Act requires that
a registered broker-dealer be a member
of a national securities association
unless the broker-dealer effects
transactions in securities solely on a
national securities exchange of which it
is a member.19 SEA Rule 15b9–1
provides an exemption to the
membership requirement in Section
15(b)(8) if a broker-dealer (i) is a
member of a national securities
exchange, (ii) carries no customer
accounts, and (iii) has annual gross
income derived from purchases and
sales of securities otherwise than on a
national securities exchange of which it
is a member in an amount no greater
than $1,000.20
On March 25, 2015, the SEC proposed
amendments to SEA Rule 15b9–1 that
would significantly narrow the
exemption from association
membership by replacing the $1,000
gross income provision in the rule with
a provision that exempts from
association membership exchange
member broker-dealers that operate on
the floor of an exchange to the extent
they effect transactions off-exchange
solely for the purpose of hedging the
risks of their floor-based activities.21 If
adopted, the amendments generally
would require a proprietary trading firm
(i.e., a firm that carries no customer
accounts and, instead, trades solely for
its own account(s)) relying on the
current exemption to become a FINRA
member if the firm continues to engage
in over-the-counter trading or trading on
an exchange of which it is not a
member.
If this, or a substantially similar,
amendment to SEA Rule 15b9–1 were
adopted by the SEC, it is likely that
many firms that are not currently FINRA
members would become FINRA
17 FINRA notes that, under SEC Rule 613, all U.S.registered broker-dealers are subject to the CAT
reporting requirements. See 17 CFR 242.613(c)(2).
Consequently, if the CAT plan submitted by the
SROs is approved, firms will need to specifically
identify each broker-dealer from which an order is
received or to which an order is routed.
18 17 CFR 240.15b9–1.
19 15 U.S.C. 78o(b)(8). FINRA is currently the only
registered national securities association.
20 17 CFR 240.15b9–1. The $1,000 gross income
limitation does not apply to income derived from
transactions for the dealer’s own account with or
through another registered broker or dealer. Thus,
for example, income derived from over-the-counter
trades through an alternative trading system does
not count toward the $1,000 threshold.
21 See Securities Exchange Act Release No. 74581
(March 25, 2015), 80 FR 18036, 18045–46 (April 2,
2015).
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9547
members and, as a result, would be
identified on OATS reports in addition
to submitting OATS reports themselves.
Even if amendments to SEA Rule 15b9–
1 are adopted, there would likely still be
some firms that do not become FINRA
members, and the timeline for
compliance with any potential
amendments to SEA Rule 15b9–1, could
be substantial. Consequently, FINRA
believes that the proposed rule change
is necessary regardless of the pending
proposed amendments to SEA Rule
15b9–1 and would remain necessary
even if amendments are subsequently
adopted by the SEC.
Although this proposed rule change
will require Reporting Members to
submit an additional data field when
submitting an OATS report for an order
received from a Reportable NonMember, FINRA does not believe that
the proposed rule change will have a
significant operational impact on
Reporting Members or their reporting
practices.22 Because identifiers already
have been assigned to Reportable NonMembers, are generally readily
ascertainable by Reporting Members,
and OATS will accept submission of
any of these identifiers already in use,
FINRA anticipates that the expense
associated with reporting this additional
data will be minimal. FINRA also notes
that some Reporting Members already
provide identifiers on their OATS
reports for orders received from NonMember Firms.23 Finally, if a Reportable
Non-Member is a member of multiple
SROs or has multiple SRO-assigned
identifiers, the Reporting Member could
use any of those identifiers to fulfill its
reporting obligation in addition to a
CRD number. As noted below, FINRA
also intends to provide a list of
Reportable Non-Members’ CRD numbers
for Reporting Members to use to aid in
implementing the proposed rule change.
As noted in Item 2 of this filing, if the
Commission approves the proposed rule
change, FINRA will announce the
effective date of the proposed rule no
later than 60 days following
Commission approval. The effective
date will be no later than 120 days
following Commission approval.
22 FINRA also does not anticipate that the change
to the OATS Reporting Technical Specifications to
require that Reporting Members report a unique
identifier when routing an order to a Non-Member
Firm will significantly impact Reporting Members’
reporting practices, as only a relatively small
amount of order flow is typically routed from
members to Non-Member Firms. In the fourth
quarter of 2014, only 1.16% of all routes reported
to OATS were reported as being routed to a NonMember Firm.
23 In the fourth quarter of 2014, ATSs reported the
SRO-assigned identifiers of seventeen Non-Member
Firms that submitted approximately 12.45 billion
orders to those ATSs.
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2. Statutory Basis
FINRA believes that the proposed rule
change is consistent with the provisions
of Section 15A(b)(6) of the Act,24 which
requires, among other things, that
FINRA rules must be designed to
prevent fraudulent and manipulative
acts and practices, to promote just and
equitable principles of trade, and, in
general, to protect investors and the
public interest. FINRA believes that the
proposed rule change will enable
FINRA to better identify a Reportable
Non-Member’s trading activity across
exchanges and in the over-the-counter
market through trades that are reported
to a FINRA facility, which will
significantly enhance FINRA’s crossmarket surveillance efforts pursuant to
its RSAs with multiple national
securities exchanges and carry out its
surveillance obligations for the over-thecounter market under its own SRO
license. As noted above, FINRA
members receive a substantial amount
of order flow from Non-Member Firms,
particularly in connection with ATS
and sponsored access activity, and the
proposed rule change will enable
FINRA to identify the activities of
Reportable Non-Members, thereby
increasing its cross-market surveillance
capabilities. Improved surveillance
capabilities help detect and deter
fraudulent and manipulative acts and
practices, promote just and equitable
principles of trade, and protect investors
and the public interest.
B. Self-Regulatory Organization’s
Statement on Burden on Competition
FINRA does not believe that the
proposed rule change will result in any
burden on competition that is not
necessary or appropriate in furtherance
of the purposes of the Act.
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Economic Impact Assessment
1. Regulatory Need
As discussed above, under the current
rules, Reporting Members report orders
they receive from, or route to, NonMember Firms but these reports do not
always contain the identity of the NonMember Firm. As a result, FINRA
cannot consistently identify NonMember Firm activity and cannot see a
complete view of such activities across
all exchanges and over-the-counter
market centers. The proposed rule
change will address these current gaps
in order reporting by requiring
Reporting Members to identify
Reportable Non-Members in their OATS
reports. Reporting this information will
allow FINRA to obtain the identity of
24 15
U.S.C. 78o–3(b)(6).
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the Reportable Non-Member directly
from the OATS data, thereby improving
FINRA’s ability to perform
comprehensive market surveillance and
increasing investor protection.
2. Economic Impacts
The proposed rule change would
impact Reporting Members that report
orders received from, or routed to,
Reportable Non-Members. As a baseline,
FINRA estimates that, in the fourth
quarter of 2014, approximately 175
Reporting Members received orders
from Non-Member Firms and
approximately 215 Reporting Members
routed orders to Non-Member Firms. As
discussed above, FINRA estimates that
over 33% of the total OATS orders in
the fourth quarter of 2014 were reported
as being received from a Non-Member
Firm. Non-Member Firm orders
accounted for a higher proportion (over
45%) of ATS orders. In addition, during
that quarter approximately 13% of
sponsored access orders were received
from a Non-Member Firm. Reporting
Members currently report orders
received from or routed to Non-Member
Firms but are not required to
specifically identify these firms in their
OATS reports. The proposed rule
change would require the Reporting
Members to identify Reportable NonMembers and submit an SRO-assigned
identifier or the CRD number of these
firms.
(i) Anticipated Benefits
The proposed rule change would
enhance FINRA’s cross-market and
over-the-counter surveillance efforts by
allowing FINRA to identify more NonMember Firm trading activity across
exchanges and the over-the-counter
market. As discussed above, FINRA
members receive a substantial amount
of order flow from Non-Member Firms,
particularly in connection with ATS
activity. The proposed rule change will
enable FINRA to identify these activities
from Reportable Non-Members, thereby
significantly improving FINRA’s ability
to support cross-market surveillance
and monitor over-the-counter trading
activity.
(ii) Anticipated Costs
As a result of the proposed rule
change, Reporting Members that are not
already identifying Reportable NonMembers in their OATS reports will
incur certain implementation costs and
on-going compliance costs associated
with identifying Reportable NonMembers and submitting identifiers on
their OATS reports.
FINRA anticipates that the costs
associated with identifying Reportable
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Non-Members will likely be minimal
because identifiers have already been
assigned to Reportable Non-Members
and these identifiers are generally
readily available to the Reporting
Member that is receiving orders from or
routing orders to Reportable NonMembers. In addition, the proposed rule
change would provide Reporting
Members with the option to report
either the CRD number or the SRO
assigned identifier, thereby allowing
them to submit the identifiers that are
already in use.25 Moreover, FINRA
intends to provide a list of CRD
numbers to assist further in
implementing the new requirements for
those firms that are not already
identifying Reportable Non-Members on
their OATS reports, thereby further
reducing the burden to ascertain
appropriate identifiers for Reportable
Non-Members.
FINRA recognizes that some
Reporting Members may need to update
their reporting systems and would incur
certain costs associated with system
analysis, coding, and testing in order to
submit the required identifiers on their
OATS reports. However, based on the
provision of the list of identifiers by
FINRA, the current volume of OATS
Reports already submitted with NonMember Firm information, and the
Staff’s experience with previous
changes to the OATS requirements
requiring similar modification to OATS
reporting (i.e., modifications requiring
new values for existing fields), FINRA
believes that significant coding and
development would not be required and
that the costs referenced above would
likely be minimal. Based on OATS data
for the fourth quarter of 2014, FINRA
estimates that approximately 23% of
Reporting Members that receive orders
from Non-Member Firms already
identify these firms on their OATS
reports and approximately 12% of
Reporting Members that route orders to
Non-Member Firms identify these firms
on their OATS reports.26
3. Alternatives
In considering the best way to meet its
regulatory objectives, FINRA considered
certain alternatives to particular features
25 Reporting Members would, therefore, have
flexibility in determining which identifiers to
submit, which is intended to reduce costs for these
firms by allowing them to choose the most cost
effective option.
26 FINRA notes that a number of these Reporting
Members identify Non-Member Firms on some, but
not all, orders whereas others do so on all orders.
For example, in the fourth quarter of 2014, of the
39 Reporting Members that receive orders from
Non-Member Firms and identify them on their
OATS report, 28 identify Non-Member Firms on
some and 11 identify them on all orders.
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of this proposal, including alternative
identifiers that could be used to identify
Reportable Non-Members. For example,
one FINRA committee member
suggested that FINRA consider
leveraging use of a Legal Entity
Identifier (‘‘LEI’’) for identifying
Reportable Non-Members. FINRA does
not believe that use of a LEI would be
feasible at this time considering that the
LEI is not universally in use. As a result,
FINRA did not propose the use of LEI
in the OATS reports for identifying
Reportable Non-Members.
mstockstill on DSK4VPTVN1PROD with NOTICES
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
The proposed rule change, in addition
to another proposal involving ATS order
reporting, was published for comment
in Regulatory Notice 14–51 (November
2014).27 Five comments were received
in response to the Regulatory Notice; 28
however, only four of the comment
letters addressed the proposed rule
change.29 A copy of Regulatory Notice
14–51 is attached as Exhibit 2a.30 A list
of comment letters received in response
to Regulatory Notice 14–51 is attached
as Exhibit 2b, and copies of the four
comment letters that addressed the
proposed rule change are attached as
Exhibit 2c. Of the four comment letters
received that addressed the proposed
rule change, KCG and SIFMA were in
favor of the proposed rule change,
Liquidnet did not support or oppose the
proposed rule change but asked for
interpretive guidance on the application
of the proposed rule change to non-U.S.
broker-dealers, and FIF was generally
opposed.
Liquidnet and SIFMA requested that
FINRA provide guidance on the
27 The ATS order reporting proposal described in
Regulatory Notice 14–51 is not reflected in the
current proposed rule change; consequently,
comments on that proposal are not addressed.
28 See Letter from Manisha Kimmel, Managing
Director, Financial Information Forum, to Marcia E.
Asquith, Secretary, FINRA, dated February 20, 2015
(‘‘FIF’’); Letter from John A. McCarthy, General
Counsel, KCG Holdings, Inc., to Marcia E. Asquith,
Secretary, FINRA, dated February. 20, 2015
(‘‘KCG’’); Letter from Howard Meyerson, General
Counsel, Liquidnet Inc., to Marcia E. Asquith,
Secretary, FINRA, dated February 20, 2015
(‘‘Liquidnet’’); Letter from Theodore R. Lazo,
Managing Director and Associate General Counsel,
Securities Industry and Financial Markets
Association, to Marcia E. Asquith, Secretary,
FINRA, dated February 24, 2015 (‘‘SIFMA’’); and
Letter from Mark Holder, Managing Director, UBS
Securities LLC, to Marcia E. Asquith, Secretary,
FINRA, dated February 26, 2015 (‘‘UBS’’).
29 The UBS Letter addressed only the ATS order
reporting proposal in the Regulatory Notice and did
not address the proposed rule change.
30 The Commission notes that the exhibits
referred to (2a, 2b, and 2c) are exhibits to the
proposed rule change, not to this Notice.
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18:07 Feb 24, 2016
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application of the proposed rule change
to non-U.S. broker-dealers that do not
have either SRO-assigned identifiers or
CRD numbers.
As noted above, FINRA has amended
the proposed rule language from that in
Regulatory Notice 14–51 to clarify that
the specific identification of NonMember Firms applies only to U.S.registered broker-dealers that have SROassigned identifiers or CRD numbers as
well as Canadian broker-dealers who
have been assigned SRO identifiers for
purposes of accessing a FINRA trade
reporting facility pursuant to Rule
7220A or 7320. FINRA will provide an
indicator for ‘‘non-U.S. broker-dealer’’
for use in the destination code field (for
routes to a non-member broker-dealer)
and as a member type code (for orders
received from a non-member brokerdealer) so that Reporting Members can
reflect routes to or from a non-U.S.
broker-dealer that does not have a CRD
number or an SRO-assigned identifier.
FIF noted that using SRO-assigned
identifiers would be preferable to using
CRD numbers and suggested that FINRA
provide a list of allowable identifiers.
KCG requested that FINRA develop a
list of identifiers that OATS reporting
firms could rely upon to identify nonmember broker-dealers and suggested
that only those identifiers appearing on
the list be required to be reported when
dealing with non-member brokerdealers.
In response to these comments,
FINRA intends to develop and publish
on its Web site a list of acceptable CRD
numbers for Reporting Members to use
to meet their OATS reporting
obligations. FINRA does not, however,
intend that only those identifiers
appearing on the list would be
acceptable values. For example,
Canadian broker-dealers that have been
issued MPIDs to access FINRA trade
reporting facilities pursuant to Rule
7220A or Rule 7320 do not have CRD
numbers; thus, Reporting Members
receiving orders from or routing orders
to such firms would be required to use
the Canadian firm’s MPID on their
OATS reports. Finally, FIF noted that
the issue of identifying Non-Member
Firms will be addressed upon the
implementation of the CAT and
suggested that FINRA not take interim
measures to improve OATS but ‘‘work
diligently with the other SROs towards
driving CAT forward.’’
FINRA does not view these
undertakings as mutually exclusive.
While FINRA is working diligently with
other SROs to develop and implement
the CAT, FINRA also believes that
reasonable changes to OATS should still
be made to ensure existing audit trails
PO 00000
Frm 00131
Fmt 4703
Sfmt 4703
9549
can be enhanced. As noted above, the
full implementation of the CAT is likely
still years away. FINRA strongly
believes that gaps in OATS data must be
addressed in the near-term, after
weighing the burdens to firms and the
necessity of the change, to ensure an
effective audit trail. As set forth above,
FINRA has concluded that the
identification of Reportable NonMembers is important to enhance
FINRA’s cross-market surveillance and
believes these modest changes to the
OATS requirements should not be
delayed due to the potential future
implementation of the CAT. Although
this proposed rule change will require
some Reporting Members to submit
more specific data when submitting an
OATS report for an order received from
a Reportable Non-Member, FINRA does
not believe that this change will have a
significant operational impact on
Reporting Members or their reporting
practices because identifiers already
have been assigned to the Reportable
Non-Members, are generally readily
ascertainable by the Reporting Member
that is receiving orders from or routing
orders to the Reportable Non-Member,
and OATS will accept submission of
any of these identifiers already in use.
As noted above, FINRA intends to
provide a list of CRD numbers to assist
further in implementing the new
requirements for those Reporting
Members that are not already
identifying Reportable Non-Members on
their OATS reports.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
Within 45 days of the date of
publication of this notice in the Federal
Register or within such longer period (i)
as the Commission may designate up to
90 days of such date if it finds such
longer period to be appropriate and
publishes its reasons for so finding or
(ii) as to which the self-regulatory
organization consents, the Commission
will:
(A) By order approve or disapprove
such proposed rule change, or
(B) institute proceedings to determine
whether the proposed rule change
should be disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
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9550
Federal Register / Vol. 81, No. 37 / Thursday, February 25, 2016 / Notices
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
FINRA–2016–006 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
mstockstill on DSK4VPTVN1PROD with NOTICES
All submissions should refer to File
Number SR–FINRA–2016–006. This file
number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of such
filing also will be available for
inspection and copying at the principal
office of FINRA. All comments received
will be posted without change; the
Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–FINRA–
2016–006 and should be submitted on
or before March 17, 2016.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.31
Brent J. Fields,
Secretary.
[FR Doc. 2016–03941 Filed 2–24–16; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–77196; File No. SR–FINRA–
2016–005]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Notice of Filing of a
Proposed Rule Change To Reduce the
Synchronization Tolerance for
Computer Clocks That Are Used To
Record Events in NMS Securities and
OTC Equity Securities
February 19, 2016.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that on February
9, 2016, Financial Industry Regulatory
Authority, Inc. (‘‘FINRA’’) filed with the
Securities and Exchange Commission
(‘‘SEC’’ or ‘‘Commission’’) the proposed
rule change as described in Items I, II,
and III below, which Items have been
prepared by FINRA. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
FINRA is proposing to reduce the
synchronization tolerance for members’
computer clocks that are used to record
events in NMS securities, including
standardized options, and OTC Equity
Securities. This proposal would not
change the current clock
synchronization requirement for
members’ mechanical time stamping
devices or computer clocks that are used
to record events for securities other than
NMS securities or OTC Equity
Securities.
The text of the proposed rule change
is available on FINRA’s Web site at
https://www.finra.org, at the principal
office of FINRA, on the Commission’s
Web site at https://www.sec.gov, and at
the Commission’s Public Reference
Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission,
FINRA included statements concerning
the purpose of and basis for the
proposed rule change and discussed any
comments it received on the proposed
rule change. The text of these statements
may be examined at the places specified
in Item IV below. FINRA has prepared
1 15
31 17
CFR 200.30–3(a)(12).
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18:07 Feb 24, 2016
2 17
Jkt 238001
PO 00000
U.S.C. 78s(b)(1).
CFR 240.19b–4.
Frm 00132
Fmt 4703
Sfmt 4703
summaries, set forth in sections A, B,
and C below, of the most significant
aspects of such statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
Current FINRA rules require that
firms synchronize their business clocks
in conformity with procedures
prescribed by FINRA. Specifically,
FINRA Rule 7430 requires that firms
synchronize their business clocks that
are used for purposes of recording the
date and time of any event that must be
recorded pursuant to the FINRA ByLaws or other FINRA rules (e.g., the
time a trade was executed or the time an
order was received or routed), with
reference to a time source as designated
by FINRA. As specified in the current
OATS technical specifications, all
computer system clocks and mechanical
time stamping devices must be
synchronized to within one second of
the NIST atomic clock.3 To maintain
clock synchronization, clocks should be
checked against the NIST atomic clock
and re-synchronized, if necessary, at
pre-determined intervals throughout the
day.4 FINRA understands that currently,
some firms synchronize their clocks
continuously throughout the day, while
others do so at various times during the
day and still others do so only once a
day.5
Given the increasing speed of trading
in today’s automated markets, FINRA
believes the current one second
tolerance is no longer appropriate for
computer system clocks recording
3 Any time provider may be used for
synchronization; however, all clocks and time
stamping devices must remain accurate within a
one-second tolerance of the NIST clock. This
tolerance includes (1) the difference between the
NIST standard and a time provider’s clock, (2)
transmission delay from the source and (3) the
amount of drift of the member firm’s clock. The
OATS technical specifications further specify that
computer system and mechanical clocks must be
synchronized every business day before market
open to ensure that recorded order event
timestamps are accurate.
4 The OATS technical specifications also provide
that member firms must document and maintain
their clock synchronization procedures. In addition,
the technical specifications state that member firms
should keep a log of the times when they
synchronize their clocks and the results of the
synchronization process, including notice of any
time a member’s clock drifts more than the one
second standard. The technical specifications
further provide that such logs should be maintained
for the period of time and accessibility specified in
SEC Rule 17a–4(b), and maintained and preserved
for the required time period in paper format or in
a format permitted under SEC Rule 17a–4(f).
5 FINRA generally believes that the firms that
synchronize once daily are firms that accept manual
orders.
E:\FR\FM\25FEN1.SGM
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Agencies
[Federal Register Volume 81, Number 37 (Thursday, February 25, 2016)]
[Notices]
[Pages 9545-9550]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-03941]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-77180; File No. SR-FINRA-2016-006]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Notice of Filing of a Proposed Rule Change To Amend
FINRA Rules 7410 (Definitions) and 7440 (Recording of Order
Information)
February 19, 2016.
Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
(``Act'') \1\ and Rule 19b-4 thereunder,\2\ notice is hereby given that
on February 11, 2016, Financial Industry Regulatory Authority, Inc.
(``FINRA'') filed with the Securities and Exchange Commission (``SEC''
or ``Commission'') the proposed rule change as described in Items I,
II, and III below, which Items have been prepared by FINRA. The
Commission is publishing this notice to solicit comments on the
proposed rule change from interested persons.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
---------------------------------------------------------------------------
I. Self-Regulatory Organization's Statement of the Terms of Substance
of the Proposed Rule Change
FINRA is proposing to amend FINRA Rules 7410 and 7440 to require
FINRA members to identify on their Order Audit Trail System (``OATS'')
reports the identity of certain broker-dealers that are not FINRA
members when the member has received an order from such a broker-
dealer.
Below is the text of the proposed rule change. Proposed new
language is in italics; proposed deletions are in brackets.
* * * * *
7000. CLEARING, TRANSACTION AND ORDER DATA REQUIREMENTS, AND FACILITY
CHARGES
* * * * *
7400. ORDER AUDIT TRAIL SYSTEM
* * * * *
7410. Definitions
(a) through (o) No Change.
(p) ``SRO-assigned identifier'' shall mean a unique identifier
assigned to a broker or dealer by a national securities exchange or
national securities association for use by such broker or dealer when
accessing the exchange or a facility of the association.
* * * * *
7440. Recording of Order Information
(a) No Change.
(b) Order Origination and Receipt
Unless otherwise indicated, the following order information must be
recorded under this Rule when an order is received or originated. For
purposes of this Rule, the order origination or receipt time is the
time the order is received from the customer.
(1) through (17) No Change.
(18) the type of account, i.e., retail, wholesale, employee,
proprietary, or any other type of account designated by FINRA, for
which the order is submitted; [and]
(19) when the Reporting Member receives an order from a U.S.-
registered broker-dealer that is not a member, or from a non-U.S.-
registered broker-dealer that is not a member but has received an SRO-
assigned identifier for purposes of accessing a FINRA facility pursuant
to Rule 7220A or 7320, identification of such broker-dealer by
providing an SRO-assigned identifier assigned to the broker-dealer or
the number assigned to the broker-dealer in the Central Registration
Depository system; and
(20) if the member is relying on the exception provided in Rule
5320.02 with respect to the order, the unique identification of any
appropriate information barriers in place at the department within the
member where the order was received or originated.
(c) through (d) No Change.
* * * * *
II. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
In its filing with the Commission, FINRA included statements
concerning the purpose of and basis for the proposed rule change and
discussed any comments it received on the proposed rule change. The
text of these statements may be examined at the places specified in
Item IV below. FINRA has prepared summaries, set forth in sections A,
B, and C below, of the most significant aspects of such statements.
A. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
1. Purpose
FINRA is proposing an amendment to Rule 7440 of the OATS rules to
require FINRA members subject to the OATS rules (``Reporting Members'')
to specifically identify two types of non-FINRA-member broker-dealers
(``Non-Member Firms'') as part of the OATS report when they receive
orders from
[[Page 9546]]
these firms.\3\ Under the proposed rule change, Reporting Members
receiving an order from either a U.S.-registered broker-dealer that is
not a FINRA member or a broker-dealer that is not registered in the
U.S. but has received an SRO-assigned identifier \4\ in order to access
certain FINRA trade reporting facilities (each a ``Reportable Non-
Member'') must identify the broker-dealer when reporting receipt of the
order to OATS.\5\ Pursuant to the proposed rule change, and as
described below, Reporting Members receiving an order from or routing
an order to a Non-Member Firm would therefore report one of the
following: The Non-Member Firm's Central Registration Depository
(``CRD[supreg]'') number; an SRO-assigned identifier assigned to the
Non-Member Firm; or, for a Non-Member Firm that does not have a CRD
number or SRO-assigned identifier (e.g., a foreign broker-dealer), a
value indicating that the Non-Member Firm has no CRD number or SRO-
assigned identifier. Reporting this information will allow FINRA to
obtain the identity of Reportable Non-Members directly from the OATS
report.
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\3\ FINRA Rule 7410(o) defines a Reporting Member as ``a member
that receives or originates an order and has an obligation to report
information under Rules 7440 and 7450.'' The rule also contains
exceptions from the rule. See FINRA Rule 7410(o)(1) and (2).
\4\ FINRA is proposing to define an ``SRO-assigned identifier''
in Rule 7410 as ``a unique identifier assigned to a broker or dealer
by a national securities exchange or national securities association
for use by such broker or dealer when accessing the exchange or a
facility of the association.'' For purposes of the definition, the
identifier is ``unique'' provided the identifier assigned by the
exchange or association is used to identify only a single broker-
dealer.
\5\ Certain broker-dealers registered in Canada, but not in the
U.S., have SRO-assigned identifiers so that they can access FINRA
trade reporting facilities pursuant to FINRA Rule 7220A or 7320.
---------------------------------------------------------------------------
A Reporting Member receiving an order from a Reportable Non-Member
would include on its OATS report either the SRO-assigned identifier
(e.g., a market participant identifier (``MPID'') assigned by a
national securities exchange) or the Reportable Non-Member's CRD
number.\6\ The proposed rule change does not mandate which identifier
Reporting Members must use; thus, Reporting Members may use either an
existing SRO-assigned identifier or a CRD number on their OATS reports
to identify the Reportable Non-Member. If a Reportable Non-Member does
not have an SRO-assigned identifier that is available to FINRA, the
Reporting Member receiving the order would be required to report the
CRD number of the Reportable Non-Member.\7\ Similarly, for a non-U.S.-
registered broker-dealer that has an SRO-assigned identifier in order
to access a FINRA trade reporting facility pursuant to Rule 7220A or
7320 but does not have a CRD number, the Reporting Member receiving the
order would be required to report the SRO-assigned identifier for the
broker-dealer.
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\6\ To register as a broker-dealer and have a CRD number, firms
are required to file a Form BD with CRD. See 17 CFR 240.15b1-1(b).
Consequently, all U.S.-registered broker-dealers have a CRD number.
Currently, all U.S.-registered broker-dealers also have at least one
SRO-assigned identifier that is available to FINRA.
\7\ Because non-U.S. broker-dealers generally do not have SRO-
assigned identifiers or CRD numbers, the proposed rule change would
not require specific identification of non-U.S. broker-dealers when
those firms do not have SRO-assigned identifiers or CRD numbers. In
these cases, FINRA intends to permit a value whereby the Reporting
Member would indicate the order was received from a non-U.S. broker-
dealer without a CRD number or SRO-assigned identifier.
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FINRA is filing the proposed rule change to enhance its market
surveillance efforts, both under its own SRO license and pursuant to
its Regulatory Service Agreements (``RSAs'') with multiple national
securities exchanges, by being able to identify more Non-Member Firm
trading activity across exchanges and in the over-the-counter market
through trades that are reported to a FINRA trade reporting
facility.\8\ Through OATS, FINRA is currently able to identify in
detail the order and trading activity of FINRA member broker-dealers
across market centers. Using data provided by the exchanges as well as
CRD numbers, FINRA is also able to identify in detail the trading
activities of Non-Member Firms and aggregate these firms' activities
across RSA client exchanges.\9\ Although Reporting Members report
orders they receive from, or route to, Non-Member Firms, these reports
do not always contain the identity of the Non-Member Firm from whom the
order was received, or to whom it was routed.\10\ FINRA cannot,
therefore, currently identify in detail Non-Member Firm activity in the
over-the-counter market, or Non-Member Firm sponsored access activity,
since Reporting Members are not required to report to OATS the identity
of Non-Member Firms. Consequently, FINRA is not able to consistently
identify Non-Member Firm activity and does not have a complete view of
such activities across all exchanges and over-the-counter market
centers. As the Commission recently noted when it proposed amendments
to SEA Rule 15b9-1,\11\ ``FINRA's ability to perform comprehensive
market surveillance, especially for violations of Commission rules, as
well as its ability to understand and reconstruct activity in the off-
exchange market generally, is limited because [Non-Member Firms] are
not consistently identified in trade reports to the TRFs or the ADF,
and their order activity is not captured by OATS.'' \12\
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\8\ FINRA obtains exchange data pursuant to RSAs it has signed
with certain client exchanges. Under the current RSAs with national
securities exchanges, FINRA conducts comprehensive surveillance
across more than 99% of the market for U.S. listed equities by share
and trade volume.
\9\ This is accomplished by using exchange-assigned identifiers
that are mapped to the firm's CRD number. FINRA has access to all
SRO-assigned equity identifiers with the exception of those assigned
by the Chicago Stock Exchange. Under the proposed rule change, FINRA
would thus be able to use any of these SRO-assigned identifiers or a
CRD number to obtain the identity of the Non-Member Firm on OATS
reports. A FINRA member that provides sponsored access to a Non-
Member Firm has an OATS reporting obligation for each order sent to
a national securities exchange pursuant to any such agreement. In
this scenario, the FINRA member must report a New Order and a Route
Report to the applicable exchange reflecting that the order was
received from a Non-Member Firm. See OATS FAQ C77.
\10\ Although some Reporting Members voluntarily provide the
MPID of a Non-Member Firm if one exists, the OATS rules do not
require that the identity of the Non-Member Firm be reported.
\11\ 17 CFR 240.15b9-1.
\12\ See Securities Exchange Act Release No. 74581 (March 25,
2015), 80 FR 18036, 18043 (April 2, 2015).
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In addition to amending Rule 7440 to require the identification of
Reportable Non-Members from which an order is received, FINRA is also
planning to update the OATS Reporting Technical Specifications to
require that OATS reports specifically identify a Reportable Non-Member
to which an order is routed. Rule 7440(c)(6)(I) requires that, for
orders routed from a member to a non-FINRA-member, including both non-
FINRA-member broker-dealers and national securities exchanges, the
identity of the non-FINRA member to which the order was routed be
reported. Although the OATS Reporting Technical Specifications
currently require that OATS reports include a specific identifier for
each national securities exchange to which an order is routed, only a
generic identifier for Non-Member Firms is required.\13\ Consequently,
the identity of the specific Non-Member Firm to which an order is
routed is not required under the current OATS Reporting Technical
Specifications. To address this gap and to conform the reporting of
orders received from and orders routed to Non-Member Firms, in addition
to the proposed rule change, FINRA intends to update the OATS Reporting
Technical Specifications to require that Reporting Members provide
either an SRO-assigned identifier or CRD number
[[Page 9547]]
when routing an order to a Reportable Non-Member.\14\
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\13\ See OATS Reporting Technical Specifications, at 4-4, and A-
4 to A-5 (October 12, 2015 ed.).
\14\ As noted above, in the case of a non-U.S. broker-dealer
that does not have a CRD number or an SRO-assigned identifier, FINRA
will provide an indicator for ``non-U.S. broker-dealer'' for use in
the destination code field (for routes to a non-member broker-
dealer) and as a member type code (for orders received from a non-
member broker-dealer).
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The proposed rule change, along with the changes to the OATS
Reporting Technical Specifications, will significantly improve FINRA's
ability to support cross-market surveillance and monitor over-the-
counter trading activity. Reporting Members receive a substantial
amount of order flow from Non-Member Firms, particularly in connection
with alternative trading system (``ATS'') activity, and this proposed
rule change will enable FINRA to identify the activities of Reportable
Non-Members, thereby increasing its cross-market surveillance
capabilities.\15\
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\15\ For example, in the fourth quarter of 2014, over 33% of
orders reported to OATS were reported as being received from a Non-
Member Firm. Of particular note, over 45% of ATS orders were
received from a Non-Member Firm. In addition, during that quarter
approximately 13% of sponsored access orders were received from a
Non-Member Firm.
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FINRA notes that although the data required by the proposed rule
change may ultimately be captured as part of the Consolidated Audit
Trail (``CAT''), the implementation of the CAT is likely several years
away, as the national market system plan filed by the SROs still must
be published by the Commission for public notice and comment, approved
by the SEC, and, if approved, ultimately implemented pursuant to a
multi-year timeline.\16\ FINRA strongly believes that gaps in OATS data
must be addressed in the near-term, after weighing the burdens to firms
and the necessity of the change, to ensure an effective audit trail.
FINRA believes the specific identification of Reportable Non-Members is
critical to enhance FINRA's cross-market surveillance and monitoring of
the over-the-counter market and believes these changes to the OATS
requirements should not be delayed due to the potential future
implementation of the CAT.\17\
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\16\ SEC Rule 613, which sets forth the requirements for the
CAT, does not require all broker-dealers to report order information
to the CAT until three years after the CAT plan is approved. See 17
CFR 242.613(a)(vi). The SROs charged with submitting the CAT plan
filed an initial plan with the Commission on September 30, 2014, an
amended and restated plan on February 27, 2015, and further
amendments on December 23, 2015; however, the Commission has not yet
published the CAT plan in the Federal Register for public comment.
Pursuant to the plan submitted by the SROs, once the CAT is fully
implemented, FINRA intends to sunset the OATS rules.
\17\ FINRA notes that, under SEC Rule 613, all U.S.-registered
broker-dealers are subject to the CAT reporting requirements. See 17
CFR 242.613(c)(2). Consequently, if the CAT plan submitted by the
SROs is approved, firms will need to specifically identify each
broker-dealer from which an order is received or to which an order
is routed.
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In addition to the CAT, the proposed rule change could also be
affected by any amendments to SEA Rule 15b9-1.\18\ Section 15(b)(8) of
the Act requires that a registered broker-dealer be a member of a
national securities association unless the broker-dealer effects
transactions in securities solely on a national securities exchange of
which it is a member.\19\ SEA Rule 15b9-1 provides an exemption to the
membership requirement in Section 15(b)(8) if a broker-dealer (i) is a
member of a national securities exchange, (ii) carries no customer
accounts, and (iii) has annual gross income derived from purchases and
sales of securities otherwise than on a national securities exchange of
which it is a member in an amount no greater than $1,000.\20\
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\18\ 17 CFR 240.15b9-1.
\19\ 15 U.S.C. 78o(b)(8). FINRA is currently the only registered
national securities association.
\20\ 17 CFR 240.15b9-1. The $1,000 gross income limitation does
not apply to income derived from transactions for the dealer's own
account with or through another registered broker or dealer. Thus,
for example, income derived from over-the-counter trades through an
alternative trading system does not count toward the $1,000
threshold.
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On March 25, 2015, the SEC proposed amendments to SEA Rule 15b9-1
that would significantly narrow the exemption from association
membership by replacing the $1,000 gross income provision in the rule
with a provision that exempts from association membership exchange
member broker-dealers that operate on the floor of an exchange to the
extent they effect transactions off-exchange solely for the purpose of
hedging the risks of their floor-based activities.\21\ If adopted, the
amendments generally would require a proprietary trading firm (i.e., a
firm that carries no customer accounts and, instead, trades solely for
its own account(s)) relying on the current exemption to become a FINRA
member if the firm continues to engage in over-the-counter trading or
trading on an exchange of which it is not a member.
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\21\ See Securities Exchange Act Release No. 74581 (March 25,
2015), 80 FR 18036, 18045-46 (April 2, 2015).
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If this, or a substantially similar, amendment to SEA Rule 15b9-1
were adopted by the SEC, it is likely that many firms that are not
currently FINRA members would become FINRA members and, as a result,
would be identified on OATS reports in addition to submitting OATS
reports themselves. Even if amendments to SEA Rule 15b9-1 are adopted,
there would likely still be some firms that do not become FINRA
members, and the timeline for compliance with any potential amendments
to SEA Rule 15b9-1, could be substantial. Consequently, FINRA believes
that the proposed rule change is necessary regardless of the pending
proposed amendments to SEA Rule 15b9-1 and would remain necessary even
if amendments are subsequently adopted by the SEC.
Although this proposed rule change will require Reporting Members
to submit an additional data field when submitting an OATS report for
an order received from a Reportable Non-Member, FINRA does not believe
that the proposed rule change will have a significant operational
impact on Reporting Members or their reporting practices.\22\ Because
identifiers already have been assigned to Reportable Non-Members, are
generally readily ascertainable by Reporting Members, and OATS will
accept submission of any of these identifiers already in use, FINRA
anticipates that the expense associated with reporting this additional
data will be minimal. FINRA also notes that some Reporting Members
already provide identifiers on their OATS reports for orders received
from Non-Member Firms.\23\ Finally, if a Reportable Non-Member is a
member of multiple SROs or has multiple SRO-assigned identifiers, the
Reporting Member could use any of those identifiers to fulfill its
reporting obligation in addition to a CRD number. As noted below, FINRA
also intends to provide a list of Reportable Non-Members' CRD numbers
for Reporting Members to use to aid in implementing the proposed rule
change.
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\22\ FINRA also does not anticipate that the change to the OATS
Reporting Technical Specifications to require that Reporting Members
report a unique identifier when routing an order to a Non-Member
Firm will significantly impact Reporting Members' reporting
practices, as only a relatively small amount of order flow is
typically routed from members to Non-Member Firms. In the fourth
quarter of 2014, only 1.16% of all routes reported to OATS were
reported as being routed to a Non-Member Firm.
\23\ In the fourth quarter of 2014, ATSs reported the SRO-
assigned identifiers of seventeen Non-Member Firms that submitted
approximately 12.45 billion orders to those ATSs.
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As noted in Item 2 of this filing, if the Commission approves the
proposed rule change, FINRA will announce the effective date of the
proposed rule no later than 60 days following Commission approval. The
effective date will be no later than 120 days following Commission
approval.
[[Page 9548]]
2. Statutory Basis
FINRA believes that the proposed rule change is consistent with the
provisions of Section 15A(b)(6) of the Act,\24\ which requires, among
other things, that FINRA rules must be designed to prevent fraudulent
and manipulative acts and practices, to promote just and equitable
principles of trade, and, in general, to protect investors and the
public interest. FINRA believes that the proposed rule change will
enable FINRA to better identify a Reportable Non-Member's trading
activity across exchanges and in the over-the-counter market through
trades that are reported to a FINRA facility, which will significantly
enhance FINRA's cross-market surveillance efforts pursuant to its RSAs
with multiple national securities exchanges and carry out its
surveillance obligations for the over-the-counter market under its own
SRO license. As noted above, FINRA members receive a substantial amount
of order flow from Non-Member Firms, particularly in connection with
ATS and sponsored access activity, and the proposed rule change will
enable FINRA to identify the activities of Reportable Non-Members,
thereby increasing its cross-market surveillance capabilities. Improved
surveillance capabilities help detect and deter fraudulent and
manipulative acts and practices, promote just and equitable principles
of trade, and protect investors and the public interest.
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\24\ 15 U.S.C. 78o-3(b)(6).
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B. Self-Regulatory Organization's Statement on Burden on Competition
FINRA does not believe that the proposed rule change will result in
any burden on competition that is not necessary or appropriate in
furtherance of the purposes of the Act.
Economic Impact Assessment
1. Regulatory Need
As discussed above, under the current rules, Reporting Members
report orders they receive from, or route to, Non-Member Firms but
these reports do not always contain the identity of the Non-Member
Firm. As a result, FINRA cannot consistently identify Non-Member Firm
activity and cannot see a complete view of such activities across all
exchanges and over-the-counter market centers. The proposed rule change
will address these current gaps in order reporting by requiring
Reporting Members to identify Reportable Non-Members in their OATS
reports. Reporting this information will allow FINRA to obtain the
identity of the Reportable Non-Member directly from the OATS data,
thereby improving FINRA's ability to perform comprehensive market
surveillance and increasing investor protection.
2. Economic Impacts
The proposed rule change would impact Reporting Members that report
orders received from, or routed to, Reportable Non-Members. As a
baseline, FINRA estimates that, in the fourth quarter of 2014,
approximately 175 Reporting Members received orders from Non-Member
Firms and approximately 215 Reporting Members routed orders to Non-
Member Firms. As discussed above, FINRA estimates that over 33% of the
total OATS orders in the fourth quarter of 2014 were reported as being
received from a Non-Member Firm. Non-Member Firm orders accounted for a
higher proportion (over 45%) of ATS orders. In addition, during that
quarter approximately 13% of sponsored access orders were received from
a Non-Member Firm. Reporting Members currently report orders received
from or routed to Non-Member Firms but are not required to specifically
identify these firms in their OATS reports. The proposed rule change
would require the Reporting Members to identify Reportable Non-Members
and submit an SRO-assigned identifier or the CRD number of these firms.
(i) Anticipated Benefits
The proposed rule change would enhance FINRA's cross-market and
over-the-counter surveillance efforts by allowing FINRA to identify
more Non-Member Firm trading activity across exchanges and the over-
the-counter market. As discussed above, FINRA members receive a
substantial amount of order flow from Non-Member Firms, particularly in
connection with ATS activity. The proposed rule change will enable
FINRA to identify these activities from Reportable Non-Members, thereby
significantly improving FINRA's ability to support cross-market
surveillance and monitor over-the-counter trading activity.
(ii) Anticipated Costs
As a result of the proposed rule change, Reporting Members that are
not already identifying Reportable Non-Members in their OATS reports
will incur certain implementation costs and on-going compliance costs
associated with identifying Reportable Non-Members and submitting
identifiers on their OATS reports.
FINRA anticipates that the costs associated with identifying
Reportable Non-Members will likely be minimal because identifiers have
already been assigned to Reportable Non-Members and these identifiers
are generally readily available to the Reporting Member that is
receiving orders from or routing orders to Reportable Non-Members. In
addition, the proposed rule change would provide Reporting Members with
the option to report either the CRD number or the SRO assigned
identifier, thereby allowing them to submit the identifiers that are
already in use.\25\ Moreover, FINRA intends to provide a list of CRD
numbers to assist further in implementing the new requirements for
those firms that are not already identifying Reportable Non-Members on
their OATS reports, thereby further reducing the burden to ascertain
appropriate identifiers for Reportable Non-Members.
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\25\ Reporting Members would, therefore, have flexibility in
determining which identifiers to submit, which is intended to reduce
costs for these firms by allowing them to choose the most cost
effective option.
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FINRA recognizes that some Reporting Members may need to update
their reporting systems and would incur certain costs associated with
system analysis, coding, and testing in order to submit the required
identifiers on their OATS reports. However, based on the provision of
the list of identifiers by FINRA, the current volume of OATS Reports
already submitted with Non-Member Firm information, and the Staff's
experience with previous changes to the OATS requirements requiring
similar modification to OATS reporting (i.e., modifications requiring
new values for existing fields), FINRA believes that significant coding
and development would not be required and that the costs referenced
above would likely be minimal. Based on OATS data for the fourth
quarter of 2014, FINRA estimates that approximately 23% of Reporting
Members that receive orders from Non-Member Firms already identify
these firms on their OATS reports and approximately 12% of Reporting
Members that route orders to Non-Member Firms identify these firms on
their OATS reports.\26\
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\26\ FINRA notes that a number of these Reporting Members
identify Non-Member Firms on some, but not all, orders whereas
others do so on all orders. For example, in the fourth quarter of
2014, of the 39 Reporting Members that receive orders from Non-
Member Firms and identify them on their OATS report, 28 identify
Non-Member Firms on some and 11 identify them on all orders.
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3. Alternatives
In considering the best way to meet its regulatory objectives,
FINRA considered certain alternatives to particular features
[[Page 9549]]
of this proposal, including alternative identifiers that could be used
to identify Reportable Non-Members. For example, one FINRA committee
member suggested that FINRA consider leveraging use of a Legal Entity
Identifier (``LEI'') for identifying Reportable Non-Members. FINRA does
not believe that use of a LEI would be feasible at this time
considering that the LEI is not universally in use. As a result, FINRA
did not propose the use of LEI in the OATS reports for identifying
Reportable Non-Members.
C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants, or Others
The proposed rule change, in addition to another proposal involving
ATS order reporting, was published for comment in Regulatory Notice 14-
51 (November 2014).\27\ Five comments were received in response to the
Regulatory Notice; \28\ however, only four of the comment letters
addressed the proposed rule change.\29\ A copy of Regulatory Notice 14-
51 is attached as Exhibit 2a.\30\ A list of comment letters received in
response to Regulatory Notice 14-51 is attached as Exhibit 2b, and
copies of the four comment letters that addressed the proposed rule
change are attached as Exhibit 2c. Of the four comment letters received
that addressed the proposed rule change, KCG and SIFMA were in favor of
the proposed rule change, Liquidnet did not support or oppose the
proposed rule change but asked for interpretive guidance on the
application of the proposed rule change to non-U.S. broker-dealers, and
FIF was generally opposed.
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\27\ The ATS order reporting proposal described in Regulatory
Notice 14-51 is not reflected in the current proposed rule change;
consequently, comments on that proposal are not addressed.
\28\ See Letter from Manisha Kimmel, Managing Director,
Financial Information Forum, to Marcia E. Asquith, Secretary, FINRA,
dated February 20, 2015 (``FIF''); Letter from John A. McCarthy,
General Counsel, KCG Holdings, Inc., to Marcia E. Asquith,
Secretary, FINRA, dated February. 20, 2015 (``KCG''); Letter from
Howard Meyerson, General Counsel, Liquidnet Inc., to Marcia E.
Asquith, Secretary, FINRA, dated February 20, 2015 (``Liquidnet'');
Letter from Theodore R. Lazo, Managing Director and Associate
General Counsel, Securities Industry and Financial Markets
Association, to Marcia E. Asquith, Secretary, FINRA, dated February
24, 2015 (``SIFMA''); and Letter from Mark Holder, Managing
Director, UBS Securities LLC, to Marcia E. Asquith, Secretary,
FINRA, dated February 26, 2015 (``UBS'').
\29\ The UBS Letter addressed only the ATS order reporting
proposal in the Regulatory Notice and did not address the proposed
rule change.
\30\ The Commission notes that the exhibits referred to (2a, 2b,
and 2c) are exhibits to the proposed rule change, not to this
Notice.
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Liquidnet and SIFMA requested that FINRA provide guidance on the
application of the proposed rule change to non-U.S. broker-dealers that
do not have either SRO-assigned identifiers or CRD numbers.
As noted above, FINRA has amended the proposed rule language from
that in Regulatory Notice 14-51 to clarify that the specific
identification of Non-Member Firms applies only to U.S.-registered
broker-dealers that have SRO-assigned identifiers or CRD numbers as
well as Canadian broker-dealers who have been assigned SRO identifiers
for purposes of accessing a FINRA trade reporting facility pursuant to
Rule 7220A or 7320. FINRA will provide an indicator for ``non-U.S.
broker-dealer'' for use in the destination code field (for routes to a
non-member broker-dealer) and as a member type code (for orders
received from a non-member broker-dealer) so that Reporting Members can
reflect routes to or from a non-U.S. broker-dealer that does not have a
CRD number or an SRO-assigned identifier.
FIF noted that using SRO-assigned identifiers would be preferable
to using CRD numbers and suggested that FINRA provide a list of
allowable identifiers. KCG requested that FINRA develop a list of
identifiers that OATS reporting firms could rely upon to identify non-
member broker-dealers and suggested that only those identifiers
appearing on the list be required to be reported when dealing with non-
member broker-dealers.
In response to these comments, FINRA intends to develop and publish
on its Web site a list of acceptable CRD numbers for Reporting Members
to use to meet their OATS reporting obligations. FINRA does not,
however, intend that only those identifiers appearing on the list would
be acceptable values. For example, Canadian broker-dealers that have
been issued MPIDs to access FINRA trade reporting facilities pursuant
to Rule 7220A or Rule 7320 do not have CRD numbers; thus, Reporting
Members receiving orders from or routing orders to such firms would be
required to use the Canadian firm's MPID on their OATS reports.
Finally, FIF noted that the issue of identifying Non-Member Firms will
be addressed upon the implementation of the CAT and suggested that
FINRA not take interim measures to improve OATS but ``work diligently
with the other SROs towards driving CAT forward.''
FINRA does not view these undertakings as mutually exclusive. While
FINRA is working diligently with other SROs to develop and implement
the CAT, FINRA also believes that reasonable changes to OATS should
still be made to ensure existing audit trails can be enhanced. As noted
above, the full implementation of the CAT is likely still years away.
FINRA strongly believes that gaps in OATS data must be addressed in the
near-term, after weighing the burdens to firms and the necessity of the
change, to ensure an effective audit trail. As set forth above, FINRA
has concluded that the identification of Reportable Non-Members is
important to enhance FINRA's cross-market surveillance and believes
these modest changes to the OATS requirements should not be delayed due
to the potential future implementation of the CAT. Although this
proposed rule change will require some Reporting Members to submit more
specific data when submitting an OATS report for an order received from
a Reportable Non-Member, FINRA does not believe that this change will
have a significant operational impact on Reporting Members or their
reporting practices because identifiers already have been assigned to
the Reportable Non-Members, are generally readily ascertainable by the
Reporting Member that is receiving orders from or routing orders to the
Reportable Non-Member, and OATS will accept submission of any of these
identifiers already in use. As noted above, FINRA intends to provide a
list of CRD numbers to assist further in implementing the new
requirements for those Reporting Members that are not already
identifying Reportable Non-Members on their OATS reports.
III. Date of Effectiveness of the Proposed Rule Change and Timing for
Commission Action
Within 45 days of the date of publication of this notice in the
Federal Register or within such longer period (i) as the Commission may
designate up to 90 days of such date if it finds such longer period to
be appropriate and publishes its reasons for so finding or (ii) as to
which the self-regulatory organization consents, the Commission will:
(A) By order approve or disapprove such proposed rule change, or
(B) institute proceedings to determine whether the proposed rule
change should be disapproved.
IV. Solicitation of Comments
Interested persons are invited to submit written data, views and
arguments concerning the foregoing, including whether the proposed rule
change is consistent with the Act. Comments may be submitted by any of
the following methods:
[[Page 9550]]
Electronic Comments
Use the Commission's Internet comment form (https://www.sec.gov/rules/sro.shtml); or
Send an email to rule-comments@sec.gov. Please include
File Number SR-FINRA-2016-006 on the subject line.
Paper Comments
Send paper comments in triplicate to Secretary, Securities
and Exchange Commission, 100 F Street NE., Washington, DC 20549-1090.
All submissions should refer to File Number SR-FINRA-2016-006. This
file number should be included on the subject line if email is used. To
help the Commission process and review your comments more efficiently,
please use only one method. The Commission will post all comments on
the Commission's Internet Web site (https://www.sec.gov/rules/sro.shtml). Copies of the submission, all subsequent amendments, all
written statements with respect to the proposed rule change that are
filed with the Commission, and all written communications relating to
the proposed rule change between the Commission and any person, other
than those that may be withheld from the public in accordance with the
provisions of 5 U.S.C. 552, will be available for Web site viewing and
printing in the Commission's Public Reference Room, 100 F Street NE.,
Washington, DC 20549, on official business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of such filing also will be available
for inspection and copying at the principal office of FINRA. All
comments received will be posted without change; the Commission does
not edit personal identifying information from submissions. You should
submit only information that you wish to make available publicly. All
submissions should refer to File Number SR-FINRA-2016-006 and should be
submitted on or before March 17, 2016.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\31\
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\31\ 17 CFR 200.30-3(a)(12).
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Brent J. Fields,
Secretary.
[FR Doc. 2016-03941 Filed 2-24-16; 8:45 am]
BILLING CODE 8011-01-P