Vendor Display Rule

Regulatory Obligations and Related Considerations

Regulatory Obligations

Rule 603 of Regulation NMS (Vendor Display Rule) generally requires broker-dealers to provide a consolidated display of market data for NMS stocks for which they provide quotation information to customers. Rule 600(b)(14) of Regulation NMS provides that the consolidated display includes “(i) the prices, sizes, and market identifications of the national best bid and national best offer for a security; and (ii) [c]onsolidated last sale information for a security,” while Rule 600(b)(15) of Regulation NMS provides that “consolidated last sale information” includes “the price, volume, and market identification of the most recent transaction report for a security that is disseminated pursuant to an effective national market system plan.”

Related Considerations

• Which firm systems or platforms provide quotation information to customers?
• How does your firm monitor whether the current quotation information is distributed to customers?
• Does your firm make the quotation information available to customers when they are placing their orders?
• Does your firm review the quotation information received from the Securities Information Processor (SIP) or vendors to determine whether that information is in compliance with all the requirements of SEC Rule 603?

Exam Findings and Effective Practices

Exam Findings

• Failure to Provide Consolidated Display
  • Missing Consolidated Display – Failing to provide the entire consolidated display:
    • in all contexts and relevant stages in which a customer may make a trading or routing decision, (such as at point of order entry and order modification); and
    • across all platforms where customers may make a trading or routing decision (such as displaying all elements of the consolidated display on firms’ web-based but not mobile device platforms).
  • Missing Elements – Providing the consolidated display, but not including certain elements, such as:
    • national best bid and offer (NBBO) (while providing only the last sale information);
    • last sale information (while providing only the NBBO);
    • market identification for NBBO or last sale;
    • size associated with NBBO or last sale; and
    • real-time NBBO and last sale information (e.g., 15-minute delayed data).
• Insufficient WSPs – Failing to maintain WSPs to address the Vendor Display Rule, periodic testing and validation that they were providing the consolidated display, and review for timely delivery of the consolidated display to customers (including evaluating and addressing any potential system latencies).

Effective Practices

• Confirming Market Data Feeds – Confirming that firms received all market data feeds (including all exchanges) necessary to provide consolidated quote and last sale information to customers (including all prices, sizes and market identification data).
• Customer Platform Reviews – Performing a comprehensive review to confirm that firms provided the consolidated display to customers across all platforms where customers may make a trading or order-routing decision (including mobile platforms).
• Latency Monitoring – Monitoring for any delays or latency of the consolidated display, especially for mobile platforms, and then taking corrective action to confirm that the Consolidated Display information was current.
• SIP Validation – Performing periodic validation of quotation and last sale information against SIP data by creating screenshots of firms’ quotation and last sale information for each customer platform and comparing it to SIP quotation and last sale information data.
• Testing and Validation – Testing and validating the consolidated display prior to and after upgrades or enhancements to customer platforms.

Additional Resources

• Regulatory Notice 15-52 (SEC Staff Provides Insight Into Firms’ Obligations When Providing Stock Quote Information to Customers)
• Regulation NMS Topic Page