Guidance

The Reporting Firm 10 Second Compliance Report Card are monthly status reports for market participant that contain counts of properly modified late trades, late trades that were not modified, and improperly modified trades.

Reporting Firm is defined as the firm that reported the Executing Party of the trade.

Overview – FINRA’s Funding Portal Rules (FP Rules) apply to firms that register with the U.S. Securities and Exchange Commission (SEC) as funding portals pursuant to the SEC’s Regulation Crowdfunding (Reg CF) and that become FINRA FP members.

The Contra Reporting Firm 20 Minute Compliance Report Card is a monthly status report on compliance for market participants with the requirement that Contra Firms accept / decline / compare trades within 20 minutes of trade execution. It provides information about the number of trades that were accepted / declined / compared within 20 minutes of execution, along with the number of trades that were accepted / declined / compared greater than 20 minutes after execution time, as well as the percentage of those trades to total trades executed.

FINRA has enhanced its engagement with key stakeholders to provide greater transparency and foster dialogue that helps us better understand the industry and markets we regulate.

Question 1

Does FINRA Rule 3210 impose any requirement as to what specific information or data an employer member must review or monitor upon receiving duplicate copies of confirmations and statements, or the transactional data contained therein, with respect to an account subject to the rule?

Answer

The Reg NMS Trade Through Report Card is a monthly statistical report detailing the transactions in NMS Securities that appear to have been reported by your firm to a Trade Reporting Facility ("TRF") or to FINRA's Alternative Display Facility at a price that traded through at least one protected best bid or offer at the respective time of execution. If non-compliance with the Order Protection Rule of Regulation NMS is found to exist, your firm may be found to be in violation of SEC Rule 611 of Regulation NMS.

Background

In March 2017, FINRA issued a Special Notice on its engagement programs as part of FINRA360. Based on comments and suggestions regarding the usefulness of some advisory committees, their membership and their effectiveness as a vehicle for dialogue between FINRA and member firms, FINRA is making several changes.

Operational Impact of Rule Changes

 The MSRB G-32 Report Card is a monthly status report to help firms evaluate the timeliness of their required filings under Municipal Securities Rulemaking Board (MSRB) Rule G-32. Amended Rule G-32, which became effective on June 1, 2009, consolidated the filing requirements of former Rule G-36 and the official statement delivery requirements of Rule G-32.