Mr. Patrick Basilice, Chief Compliance Officer, Euronext Synapse LLC

October 1, 2018

Mr. Patrick Basilice
Chief Compliance Officer
Euronext Synapse LLC
110 Wall Street, Suite 5070
New York, NY 10005

Re: Application for Exemptive Relief from Trade Reporting Obligation for Certain Transactions on an Alternative Trading System

Dear Mr. Basilice:

The Market Regulation Department of FINRA (the “staff”) has received and reviewed your letter dated September 11, 2018, in which Euronext Synapse LLC (“Euronext”) requests exemptive relief from the FINRA trade reporting obligations pursuant to FINRA Rule 6732.

Based on the information provided in your application, and conditioned upon Euronext providing the items listed below, the staff has determined that Euronext meets the specified criteria and hereby grants, pursuant to FINRA Rule 9610, Euronext an exemption for certain transactions on the Euronext alternative trading system (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 the ATS.

  1. Euronext 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. Euronext must provide to FINRA a sample of at least two such agreements.1
  2. By November 14, 2018, Euronext shall provide to FINRA data relating to each transaction exempted pursuant to FINRA Rule 6732 occurring on Euronext for the months of September and October 2018. Thereafter, Euronext 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 of at least two written agreements as required by FINRA Rule 6732(a)(5), described in Item 1 above. If Euronext fails to provide such written attestation and sample agreements within this time frame, 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 will require further consideration and may cause us to reach a different conclusion. 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 Patrick Geraghty in Market Regulation at (240) 386-4973.

Sincerely,

Jon Kroeper
Executive Vice President
Market Regulation Department

1. Euronext is reminded that it must retain the written agreements pursuant to its books and records obligations under FINRA rules, the Exchange Act, and applicable Exchange Act rules, and must be able to produce them to FINRA upon request.

2. See Regulatory Notice 16-15 (April 2016).