FINRA Guidance on OATS Exchange Route Matching

This OATS Report describes members' OATS Exchange Route Matching (ERM) obligations when routing to a national securities exchange. The guidance contained in this OATS Report supersedes any previously published guidance related to OATS Exchange Route Matching.

As required by FINRA Rule 7440 (c)(6), when a member transmits an order to a non-member, including but not limited to a national securities exchange, the Reporting Member shall record, among other things, the routed order identifier or other unique identifier required by the non-member receiving the order, as applicable. Accordingly, any order transmitted to a national securities exchange must be reported to OATS with a Routed Order ID that represents the unique order identifier the member was required to submit with the order when it was routed to the exchange. For certain exchanges with which FINRA has a regulatory services agreement, OATS uses the Routed Order ID provided on the OATS Route or Combined Order/Route Report, along with other firm identifying information, to link the OATS order to the related order in the applicable exchange.

As described in Section 6.6 of the OATS Reporting Technical Specifications, for all orders electronically routed to one of the below listed destinations, OATS must be able to link all OATS Route and Combined Order/Route Reports to the related exchange orders:

• CBOE BYX Exchange
• CBOE BZX Exchange
• CBOE EDGA Exchange
• CBOE EDGX Exchange
• Investors Exchange
• The Nasdaq Stock Market
• Nasdaq BX
• Nasdaq PHLX
• New York Stock Exchange
• NYSE American
• NYSE Arca
• NYSE Chicago Exchange
• NYSE National Stock Exchange
• Long-Term Stock Exchange
• Members Exchange
• MIAXPearl Equities Exchange

Further, as prescribed in Section 4.2.3 of the OATS Reporting Technical Specifications, for orders routed electronically to a national securities exchange, the Routed Order ID (or combination of Routed Order ID and Connection ID) must be unique for the combination of OATS MPID, Order Sent Date, Destination Code and Exchange Participant ID.

Guidance on OATS Fields Used in Exchange Route Matching

OATS uses the Exchange Participant ID, Routed Order ID/Sent to Routed Order ID, Issue Symbol ID, Order Sent Timestamp (Date portion), and Connection ID to link to the corresponding exchange order. The following describes the specific guidance related to each field required for Exchange Route Matching.

Exchange Participant ID

FINRA requires members to report in the Exchange Participant ID field the unique identifier assigned to the member by the exchange. Accordingly, the Exchange Participant ID must be assigned to the same member firm that is submitting the OATS Route Report representing the transmittal of the order to the exchange. If a firm uses multiple identifiers to enter orders into a single exchange, the firm must report the same identifier used to route the order to the exchange on the OATS Route or Combined Order/Route Report.

Routed Order ID/Sent to Routed Order ID

For orders routed electronically to a national securities exchange, the Routed Order ID (Route Report) and Sent to Routed Order ID (Combined Order/Route Report) fields must be reported to OATS in the exact format as sent to the exchange. Firms should take note of each exchange's interface specifications regarding special characters, spaces and leading zeros as some exchange transmission protocols may remove certain characters, spaces or leading zeros. In addition, the Routed Order ID/Sent to Routed Order ID must be unique for the following combination:

• OATS MPID
• Order Sent Date
• Destination Code
• Exchange Participant ID
• Connection ID (if used)

Issue Symbol ID

Firms must report the Issue Symbol ID in the format of the primary listing exchange.

Order Sent Timestamp

Firms must include in the Order Sent Timestamp field the precise date and time the order was routed to the exchange. However, only the date portion of this field will be used for matching purposes.

Connection ID

The Connection ID 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. Since OATS requires all Routed Order IDs to be unique within the day, destination exchange and Exchange Participant ID, the Connection ID field is an optional field that firms may use to augment the Routed Order ID, if necessary, to ensure that each routed order is uniquely identified.

Exchange Route Matching Linkage Criteria

The tables below contain a field-by-field mapping for each exchange to which OATS links and publishes matching statistics.

Linking to CBOE BYX, CBOE BZX, CBOE EDGA and CBOE EDGX Exchanges

The below matrix describes the specific fields OATS will use to match Route Reports to the related order in the BATS BYX Exchange (Destination Code of 'XY'), BATS BZX Exchange (Destination Code of 'XZ'), EDGA Exchange (Destination Code of ‘XJ’), or EDGX Exchange (Destination Code of ‘XK’):

Linking to Investors Exchange

The below matrix describes the specific fields OATS will use to match Route Reports to the related order in IEX (Destination Code of ‘XV’):

Linking to The Nasdaq Stock Market, Nasdaq BX and Nasdaq PSX

The below matrix describes the specific fields OATS will use to match Route Reports to the related order in The Nasdaq Stock Market (Destination Code of ‘XQ’), Nasdaq BX (Destination Code of ‘XB’) and Nasdaq PSX (Destination Code of ‘XX’):

Linking to the NYSE, NYSE Arca, NYSE American, NYSE National, and NYSE Chicago Exchanges on the NYSE Pillar Gateway

The below matrix describes the specific fields OATS will use to match Route Reports to the related order in NYSE American (Destination Code of ‘XA’), NYSE National (Destination Code of ‘XC’), NYSE Arca (Destination Code of ‘XP’), NYSE (Destination Code of ‘XN’) and NYSE Chicago (Destination Code of ‘XM’) on the NYSE Pillar Gateway:

Linking to the Long-Term Stock Exchange

The below matrix describes the specific fields OATS will use to match Route Reports to the related order in LTSE (Destination Code of ‘XL’):

Linking to the Members Exchange

The below matrix describes the specific fields OATS will use to match Route Reports to the related order in MEMX (Destination Code of ‘XU’):

Linking to the MIAXPearl Equities Exchange

The below matrix describes the specific fields OATS will use to match Route Reports to the related order in MIAXPearl (Destination Code of ‘XH’):