Guidance
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Short sales by options professionals established during the course of bona fide market making activities are exempt from the affirmative determination requirements, regardless of whether the short sales constitute a permitted offset under Regulation T.
Requirements under NASD Rule 3030 (formerly Article III, Section 43) for investment seminar activities conducted by dually registered persons that charge fees from participants.
Clarification of NASD Notice to Members
94-44 to situations in which a dually registered person maintains discretionary trading authority, determines portfolio changes, and prepares trade instructions for customer accounts and charges the accounts an asset-based fee.
Whether a proposed standby purchase agreement entered into between affiliate of a member and an issuer in connection with a public offering of the issuer's common stock could constitute an option.
Cash rebates issued to pension plan customers with respect to secondary market transactions in outstanding securities (under former Article III, Section 24, now Rule 2740 and IM-2740).
The Daily Total Summary Data and Detail Data Download files for the OATS Compliance Report Card provide underlying totals and detail of the data contained in the monthly summary OATS Compliance Report Card.
The tables below represent the data within the Daily Totals Summary Report Card and the Detail Data Download files.
Summary Definitions and Data Fields
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Overview
This guide explains how to use FINRA's Trade Data Consistency Interactive Report Card to identify and investigate discrepancies between your firm's CAT and TRF/ORF trade records.
Regulatory Obligations
FINRA Rule 2090 (Know Your Customer) requires member firms and their associated persons to use reasonable diligence to determine the “essential facts” about every customer and “the authority of each person acting on behalf of such customer.” Regulatory Notice 11-02 (SEC Approves Consolidated FINRA Rules Governing Know-Your-Customer and Suitability Obligations) advised that firms verify the essential facts about a customer “at intervals reasonably cal