Guidance on Exchange Route Matching, Including the Addition of Exchange Participant ID

As part of the expansion of the OATS Rules to all NMS stocks, FINRA will electronically link OATS Route Reports to the related order in the applicable NYSE market, similar to orders routed to a NASDAQ market. As described in the OATS Reporting Technical Specifications published on May 3, 2011, two new fields have been added to OATS Route and Combined Order/Route Reports. The first new field is called the “Exchange Participant ID” and is required for all Route and Combined Order/Route Reports with a Destination Code representing a national securities exchange. Because the NYSE markets do not use FINRA or NASDAQ MPIDs, OATS must obtain the exchange participant identifier used by members when entering an order into a NYSE market in order to link the OATS Route Report to the related order in the NYSE market. Further, so that the OATS reporting requirements are the same for all orders routed to a national securities exchange, FINRA will require the exchange participant identifier be included on OATS Route and Combined Order/Route Reports whenever an order is routed to any national securities exchange.

OATS will reject any Route or Combined Order/Route Report that has a Destination Code of a national securities exchange but does not have the Exchange Participant ID field populated.

The second new field is called the “Connection ID” field and allows a firm to report to OATS the unique identifier representing the name of the connection used when routing an order to a national securities exchange. Because OATS will require all routed order identifiers to be unique within the day, destination exchange and Exchange Participant Identifier, the Connection ID field is an optional field that firms may use to augment the routed order identifier, if necessary, to ensure that each routed order is uniquely identified.

With the addition of these new fields, and the new requirement that the routed order identifier (or combination of routed order identifier and Connection ID) be unique within the day, destination exchange and Exchange Participant Identifier, OATS will no longer use the timestamp or share quantity as match criteria. OATS will instead use only Trade Date, Symbol, Exchange Participant ID, and Routed Order ID (or combination of Routed Order ID and Connection ID) to link OATS Route or Combined Order/Route Reports to the related order in a national securities exchange.

For routes to NASDAQ and NYSE exchanges that FINRA will electronically link to the related order in the applicable exchange system, the following fields will be used by OATS in the match process.¹

Note:  If a firm uses multiple MPIDs or mnemonics to enter orders in a single exchange, the exact identifier used for each order must be reported to OATS on the Route or Combined Order/Route Report. The exchange participant identifier is one of the match criteria, so if the same identifier is not used on both the applicable OATS report and the exchange order entry, the OATS report will be marked unmatched by OATS.

For orders routed electronically to another member or national securities exchange, the Routed Order ID and Sent to Routed Order ID fields must be unique, as per the following:

• Orders routed to another member-Routed Order ID must be unique for the following combination:
  • MPID
  • Order Sent Date
  • Sent to MPID
  • Connection ID (if used)
• Orders routed to a national securities exchange-Routed Order ID must be unique for the following combination and must be in the exact format sent to the exchange:
  • MPID
  • Order Sent Date
  • Destination Code
  • Exchange Participant ID
  • Connection ID (if used)

Please contact the OATS helpdesk at 1-800-321-6273 with any questions regarding OATS.  

¹ For information related to exchanges to which FINRA does not electronically link, firms are advised to contact the individual exchanges.

² NASDAQ generally refers to the equivalent of the Connection ID as “Account”.