TRACE Usage Reporting Policy

FINRA requires that all Vendors of TRACE market data report their Vendor and/or Subscriber Usage through the FINRA Vendor Management System, on a monthly basis. These Reports must list all Users of all Display Applications with the ability to access Real-Time TRACE Data, as well as Snapshot Data recipients, during the reporting period. Vendors must submit usage Reports for BTDS, ATDS, SPDS, and 144A Real-time Professional users (as applicable). In the event an individual Display Application is accessible on multiple Devices (i.e. desktop, smartphone, tablet, etc.) that are used by only one natural person, such Display Application shall be considered a single Display Application for reporting and payment purposes. However, multiple Display Applications from different Retransmission Vendors are each individually fee liable, regardless of whether they run on the same Device. A vendor must submit a Report even if it is reporting zero Real-time Professional users.

Based on the reported information FINRA will generate an invoice by multiplying the number of Users per Display Application (BTDS, ATDS,SPDS or 144A) and the number of Users provided with Snapshot Data by the applicable fee. Unless FINRA has a valid re-sale certificate on file for the Vendor, the invoice will include state sales tax, where applicable. Payment of the invoice is due within 30 days of the date of the invoice. Interest at the rate of 1% per month on any outstanding balance shall be due from the date thirty (30) days after the date of the invoice to the time that the amount(s) that are due have been received by FINRA. Reports are due by the 15th day of the following month for the preceding month (i.e., May 15th is the due date for April Report(s)).

For any questions or support, FINRA Vendors may contact FINRA TRACE Data Services via email

[email protected] or telephone (888) 507-3665.

Late and Revised Reporting Policy

Vendor is limited to a ninety (90) calendar day grace period in which to revise or correct its Reports to obtain credits. The grace period begins on the due date of the original Report, but is extended to the next business day if the last day of the grace period coincides with a market holiday or a weekend day. FINRA will not provide Vendor with credit for revisions or corrections to Reports received after the end of the grace period. "Revised" can include, but is not limited to, reclassification of Clients, reporting of usage under alternative pricing structures and correction of errors by Vendor. This does not in any way limit Vendor's liability to FINRA for underreporting usage.

Underreported usage must be reported immediately upon discovery, and shall accrue at an interest rate of 1% per month on the outstanding unreported usage due from 30 days after the date the usage should have been reported.