Joseph Lodato, Octaura Securities TradingCo LLC

Request for TRACE Reporting Exemption Under FINRA Rule 6732

March 26, 2025

Joseph W. Lodato
Chief Compliance Officer
Octaura Securities TradingCo LLC

5 Pennsylvania Plaza, 6th Floor
New York, NY 10001

Re: Octaura Securities TradingCo LLC (CRD No. 321877) Request for TRACE Reporting Exemption Under FINRA Rule 6732

Dear Mr. Lodato:

The staff of the Market Regulation Department (the “staff”) of the Financial Industry Regulatory Authority, Inc. (“FINRA”) has received and reviewed your letter dated November 14, 2024, in which Octaura Securities TradingCo LLC (“Octaura”) requests exemptive relief for its alternative trading system (“ATS”) (“Octaura ATS”) from the FINRA trade reporting obligations pursuant to FINRA Rule 6732.

Based on the information provided in your application, and conditioned upon Octaura providing the items listed below, the staff has determined that Octaura ATS meets the specified criteria and hereby grants, pursuant to FINRA Rule 9610, Octaura an exemption for certain transactions on the Octaura ATS from the trade reporting obligation under FINRA Rule 6730, subject to the monthly transaction reporting obligation and remission of the transaction reporting fees based on the fee schedule set forth in Rule 7730(b)(1) for each exempted sell transaction occurring on Octaura ATS.

1. Within 60 days of this letter, Octaura must provide to FINRA a written attestation that it has entered into written agreements as required by FINRA Rule 6732(a)(5) with all of its FINRA member subscribers that will be parties to an exempt transaction. Within 60 days of this letter, Octaura must provide to FINRA a sample of at least two such executed agreements.¹
2. By June 15, 2025, Octaura shall provide to FINRA data relating to each transaction exempted pursuant to FINRA Rule 6732 occurring on Octaura ATS for the months of April and May 2025. Thereafter, Octaura must provide such monthly trade information to FINRA and such information must be received by FINRA no later than the 10th business day following the completion of each calendar month.²

This exemption will be fully and finally effective upon the date that FINRA receives the written attestation and the sample executed written agreements as required by FINRA Rule 6732(a)(5), described in Item 1 above. If Octaura fails to provide such written attestation and sample executed written agreements within this timeframe, the exemption granted herein will be revoked unless otherwise expressly agreed to by FINRA.

This letter responds only to the issue you have raised based on the facts as you have described them, and does not address any other rule or interpretation of FINRA, or all the possible regulatory and legal issues involved. Any changes in the facts or representations as you have described them in your letter will require further consideration and may cause us to reach a different conclusion.³ You should contact FINRA immediately if there is a change in any of the facts or representations contained in your letter. In addition, this exemption is subject to modification or revocation if at any time FINRA determines that such action is necessary or appropriate for the protection of investors.

Should you have any questions about this letter, please contact Joseph Schwetz in Market Regulation at (240) 386-6170.

Sincerely,

Patrick Geraghty
Senior Vice President, Surveillance and Market Intelligence 
Market Regulation Department