TRACE Reporting Requirements for Certain SBA Pool Transactions

As a reminder, effective May 16, 2011, firms are required to report transactions in asset- and mortgage-backed securities—including Small Business Administration (SBA) securities—to TRACE, a FINRA-developed system that facilitates the mandatory reporting of over-the-counter transactions in eligible fixed income securities.

On occasion, SBA-approved pool assemblers effect transactions in yet-to-be-formed pools that do not have an assigned CUSIP or pool number. In the absence of these identifiers, FINRA has assigned generic “TBA” FINRA symbols that firms should use to report transactions to TRACE for yet-to-be-formed SBA pools. See the TBA category on the TRACE Issue master list for the full list of symbols.

Effective Tuesday, June 28, firms should report trades in SBA pools without CUSIP or pool numbers using FINRA TBA symbols. Please note the following when reporting such trades:

• Coupons should be rounded down to the nearest quarter point.
• Maturity dates should be rounded to the nearest five-year interval (as per the information listed in the security description).
• Currently, the settlement month is listed as “1” (January) for all TBA FINRA symbols. Please ignore this for now. The settlement month field will be set to “null” in the near future.

If you have any questions on the reporting of SBA pools using TBA FINRA symbols, please contact Justin Tubiolo via email.