Frequently Asked Questions about OTC (ATS & Non-ATS) Transparency

ATS MPID Requirement

1. My firm operates an ATS that trades both equity and fixed income Securities. Do I have to comply with the unique MPID requirement?

If an ATS reports any trade to FINRA, either to an equity trade reporting facility or to TRACE, it must comply with the MPID requirements that become effective on February 2, 2015. See Regulatory Notice 14-07.

2. My firm operates a single ATS that currently uses two MPIDs: one for fixed-income securities reported to TRACE and another for equity securities reported to one of FINRA's trade reporting facilities. Can I continue to use two MPIDs under these circumstances?

Yes. ATSs are required to use a single, unique MPID to report transactions within the ATS with one exception. ATSs are permitted to use two separate MPIDs if one is used exclusively to report transactions in debt securities to TRACE and the other is used exclusively to report transactions in equity securities to a FINRA equity trade reporting facility (i.e., one of the TRFs, the ADF, or the OTC Reporting Facility).

3. My firm is an ATS, and our sole business is operating the ATS. Our firm currently has a single MPID; however, the ATS sometimes routes orders away to fill an odd-lot portion of a customer order after the ATS crosses the round-lot portion within the ATS. My ATS also may route orders away to correct an error. In every case, these routed orders are executed outside of the ATS, and the ATS is listed as the contra-side executing broker in the trade report. Does the ATS need an additional MPID for these routed orders?

Under these circumstances, the ATS would not need an additional MPID provided that in every case where an order is routed outside of the ATS, the ATS's MPID is only ever indicated as the contra-side executing broker of a trade reported to a FINRA facility.

4. What are the OATS and trade reporting requirements for orders received directly at an ATS as well as orders routed to an ATS from another department of the firm operating ATS?

Please see the ATS OATS and Trade Reporting guidance effective as of February 2, 2015.