Regulatory Notice 12-47

FINRA and ISG Extend Effective Date for Certain Electronic Blue Sheet Data Elements

Published Date:

The effective date for compliance with certain elements identified in this Notice has been extended to May 1, 2014. See Regulatory Notice 13-38.

Effective Date: May 1, 2013

Electronic Blue Sheet Submissions

Regulatory Notice
Notice Type

Guidance		 Suggested Routing

Compliance
Legal
Operations
Senior Management
Key Topics

Blue Sheets		 Referenced Rules & Notices

FINRA Rule 8211
FINRA Rule 8213
Notice to Members 05-58
Regulatory Notice 11-56
Regulatory Notice 12-36
SEA Rule 13h-1

Executive Summary

FINRA and the other U.S. members of the Intermarket Surveillance Group (ISG members)1 have extended the effective date for compliance with certain new data elements for Electronic Blue Sheets (EBS) identified in Regulatory Notice 12-36 to May 1, 2013.

FINRA and the other ISG members note the following:

•   Required fields added to EBS record layout. The fields identified in Regulatory Notice 12-36 as modified below must be added to the EBS record layout by November 30, 2012, as currently required. However, the name and description of the Entering Firm Identifier and Executing Firm Identifier fields are being renamed as Primary Party Identifier and Contra Party Identifier fields, respectively, but the technical format specifications will remain the same. As noted below, for EBS requests from FINRA and the other ISG members, these fields are not required to be populated until May 1, 2013, and for SEC Large Trader EBS requests, these fields are not required to be populated, but at any time firms may voluntarily submit the values to the SEC and they will be accepted.
•   SEC EBS Requests. For Large Trader EBS requests from the SEC, the November 30, 2012, and May 1, 2013, effective dates and their respective requirements to populate the EBS remain unchanged.2
•   FINRA and the other ISG member EBS Requests. For EBS requests from FINRA and other ISG members, the Order Execution Time, Primary Party Identifier and Contra Party Identifier fields are not required to be populated until May 1, 2013. Firms may voluntarily submit Large Trader 1–3 and Large Trader Qualifier values to FINRA and other ISG members and they will be accepted.

Attachment A to this Notice sets forth additional modifications from Regulatory Notice 12-36 regarding changes to the EBS record layout and Attachment B outlines modifications to the Transaction Type Identifiers.

Questions concerning the EBS enhancements should be directed to [email protected].

Updated April 30, 2013: The effective date for compliance with certain elements identified in this Notice has been extended to November 1, 2013. See Regulatory Notice 13-16. Effective Dates: May 1, 2013 and November 1, 2013.

Updated November 4, 2013: The effective date for compliance with certain elements identified in this Notice has been extended to May 1, 2014. See Regulatory Notice 13-38.

Discussion

FINRA and the other ISG members have extended the effective date for compliance with certain new data elements identified in Regulatory Notice 12-36 to May 1, 2013, to allow broker-dealers additional time to implement changes to comply with the new requirements.3

The fields identified in Regulatory Notice 12-36 as modified as set forth below and in Attachment A must be added to the EBS record layout by November 30, 2012, as currently required. However, the Entering Firm Identifier and Executing Firm Identifier fields are renamed as the Primary Party Identifier and Contra Party Identifier fields, respectively, and the firm must identify the party to the trade that is represented by the Submitting Broker or Opposing Broker of an EBS, respectively. The technical format specifications for these fields will remain the same as previously announced. The firm may submit a Market Participant Identifier (MPID), Central Registration Depository (CRD) Number or Option Clearing Corporation (OCC) Clearing Number for such fields. For example, if Firm A cleared through Firm B, Firm A's MPID, CRD or OCC number would be provided in the Primary Party Identifier field and Firm B's NSCC clearing number would appear in the Submitting Broker Number field. For the other side of the trade, if Firm C clears through Firm D, Firm C's MPID, CRD or OCC number would be provided in the Contra Party Identifier field and Firm D's NSCC clearing number would appear in the Opposing Broker Number field.

For Large Trader requests from the SEC, the November 30, 2012, and May 1, 2013, effective dates and their respective requirements remain unchanged.4 By November 30, 2012, broker-dealers must be in EBS reporting compliance for the Order Execution Time, Large Trader Identification Number 1–3 and Large Trader Identification Qualifier fields as such fields may apply to all NMS securities and for all transactions effected directly or indirectly by or through:

•   Any proprietary account of a U.S. registered broker-dealer; or
•   Any account used by a customer that trades through a "sponsored access" arrangement.

By May 1, 2013, all broker-dealers, regardless of limitations noted above, must be in compliance with SEC Large Trader requirements, including EBS requirements. The Primary Party Identifier and Contra Party Identifier fields are not required to be populated in response to SEC Large Trader EBS requests, but at any time firms may voluntarily submit the values to the SEC and they will be accepted.

For EBS requests from FINRA and other ISG members, the Order Execution Time, Primary Party Identifier and Contra Party Identifier fields are not required to be populated until May 1, 2013. Firms may voluntarily submit the values before May 1 and they will be accepted. Firms may also voluntarily submit Large Trader Identification Number 1–3 and Large Trader Identification Qualifier values to FINRA at any time and other ISG members and they will be accepted.

The required EBS fields are set forth below. Also see Attachment A for details.

Order Execution Time, Record Sequence Number Five, Field Position 72 to 77
Firms should use this record to submit the order execution time in 24-hour format and in Eastern Time formatted as HHMMSS. This information is not limited to the blue sheet transactions relating to the SEC Large Trader Reporting Rule (SEA Rule 13h-1). Please note that all firms must synchronize their time clocks to the atomic clock to maintain an accurate audit trail in connection to the reported execution time.
Large Trader Identification Number 1, Record Sequence Number Seven, Field Position 2 to 14
Firms should use this record to submit the Large Trader Identification Number. This information is requested under the approved SEC Large Trader Reporting Rule (SEA Rule 13h-1) requirements.
Large Trader Identification Number 2, Record Sequence Number Seven, Field Position 15 to 27
Firms should use this record to submit the Large Trader Identification Number. This information is requested under the approved SEC Large Trader Reporting Rule (SEA Rule 13h-1) requirements.
Large Trader Identification Number 3, Record Sequence Number Seven, Field Position 28 to 40
Firms should use this record to submit the Large Trader Identification Number. This information is requested under the approved SEC Large Trader Reporting Rule (SEA Rule 13h-1) requirements.
Large Trader Identification Qualifier, Record Sequence Number Seven, Field Position 41
Firms should use this record to submit the Large Trader Identification Qualifier. If more than three LTIDs exist for a transaction, then firms should mark the field "Y" for Yes. Otherwise it should be marked "N" for No. This information is requested under the approved SEC Large Trader Reporting Rule (SEA Rule 13h-1) requirements.
Primary Party Identifier, Record Sequence Number Seven, Field Positions 42 to 49
Firms should use this record to submit the Primary Party Identifier, which provides the identity of the party to the trade that is represented by the Submitting Broker of an EBS. The firm may submit a Market Participant Identifier, Central Registration Depository Number or Option Clearing Corporation Clearing Number for this field. Please note that the Primary Party Identifier field replaces the previous Entering Firm Identifier field.
Contra Party Identifier, Record Sequence Number Seven, Field Positions 50 to 57
Firms should use this record to submit the Contra Party Identifier, which provides the identity of the contra party to the trade that is represented by the Opposing Broker of an EBS, if applicable.5 The firm may submit a Market Participant Identifier, Central Registration Depository Number or Option Clearing Corporation Clearing Number for this field. Please note that the Contra Party Identifier field replaces the previous Executing Firm Identifier field.

Consistent with Regulatory Notice 12-36, the Employer SIC Code field has been withdrawn as an EBS requirement.

The following modifications were also made to Attachment A of this Notice:

•   As noted above, the Entering Firm Identifier field has been renamed as the Primary Party Identifier field. The Primary Party Identifier provides the identity of the party to the trade that is represented by the Submitting Broker of an EBS. The firm may submit a Market Participant Identifier, Central Registration Depository Number or Option Clearing Corporation Clearing Number. The field remains in Record Sequence Number Seven, Position 42 through 49.
•   As noted above, the Executing Firm Identifier field has been renamed as the Contra Party Identifier field. The Contra Party Identifier provides the identity of the contra party to the trade that is represented by the Opposing Broker of an EBS. The firm may submit a Market Participant Identifier, Central Registration Depository Number or Option Clearing Corporation Clearing Number. The field remains in Record Sequence Number Seven, Position 50 through 57.
•   For the Strike Decimal field, the Justify column has been changed to left-justification of data.
•   For the Order Execution Time field, the Field format column has been changed to alpha-numeric.

The following modifications were made to Attachment B of this Notice:

•   The values of "M", "N", "W", "B", "O", "T", "R", "E", "F", "H", "L", "X" and "Z" have been removed as Transaction Type Identifiers. Please see NYSE Information Memorandum 12-25 for further details.
•   The value of "S" has been renamed to Designated Market Makers.
•   The value of "J" has been added to the Options column to represent Joint Back Office account that clears in the firm range at OCC.

Broker-dealers are reminded that failure to properly fill out the EBS fields is a violation of FINRA Rule 8211 and/or 8213.

Blue Sheet Submission Methodology

Currently, EBS requests are made under specific security symbols and option symbology. As noted in Regulatory Notice 12-36, firms will be required to submit EBS, when requested, using three additional formats:

1. account number and date;
2. account number, symbol and date; or
3. date range and Primary Party Identifier (a change from the Executing Firm Identifier).

Compliance with this requirement is similarly extended to May 1, 2013. As outlined in Regulatory Notice 12-36, the request by account number would require firms to identify the account number of a specific account at a firm, e.g. John Doe at CC Clearing Co. The request would cover all transactions under the John Doe account number at CC Clearing Co. To reduce data submission size, an EBS request may also ask for a specific symbol and date in connection with the account number. Additionally, EBS requests may be made for a specific review period under a primary party identifier. This request would require a firm to identify a clearing firm client's blue sheets for a set number of days, weeks or months, e.g. Firm ABC for the month of January 2011.

In addition, beginning on November 30, 2012, in response to a request from the SEC for large trader transaction records, broker-dealers must be prepared to submit blue sheet data, when requested, by large trader status, including LTID number(s).

Blue Sheet Testing

Starting on November 1, 2012, FINRA will open its customer test website to allow firms to test their enhanced blue sheets data file before submitting it to production. Firms that already have entitlement to FINRA's Regulation Filing Application can proceed with testing their EBS modifications by submitting their test data to https://regfilingtest.finra.org. To access the customer test website, firms should enter the same user ID and password they use to access the production website. Firms that do not have entitlement to FINRA's Regulation Filing Application should contact (800) 321-6273.

The Securities Industry Automation Corporation (SIAC) will also be open to receiving blue sheet test files by November 1, 2012. Firms can obtain initial testing instructions from SIAC by contacting Eugene Chernovetsky at (212) 656-2867 or [email protected] or David Savage at (212) 383-3410 or [email protected].

Frequently Asked Questions

FINRA provides answers to frequently asked questions (FAQ) on its website. The FAQs will be updated from time to time. Please see FINRA's website for the most recent version. Questions concerning the EBS enhancements should be directed to [email protected].

1 The U.S. members of the ISG include the following exchanges and self-regulatory organizations (SROs): BATS Exchange, Inc., BATS Y-Exchange, Inc., Chicago Board Options Exchange, Inc., C2 Options Exchange, Inc., CBOE Stock Exchange, LLC, Chicago Stock Exchange, Inc., EDGA Exchange, Inc., EDGX Exchange, Inc., FINRA, International Securities Exchange, LLC, The NASDAQ Stock Market LLC, NASDAQ OMX BX, Inc., NASDAQ OMX PHLX LLC, National Stock Exchange, Inc., New York Stock Exchange, LLC, NYSE MKT, LLC, NYSE Arca, Inc., and BOX Options Exchange, LLC.

2 The Securities and Exchange Commission extended the compliance date for the broker-dealer recordkeeping, reporting and monitoring requirements of Rule 13h-1 to November 30, 2012, and May 1, 2013. Please see Securities Exchange Release No. 34-66839 (April 20, 2012), 77 FR 25007 (April 26, 2012) for further details.

3Id.

4Id.

5 If a transaction is an internalized trade and there is no Opposing Broker, then the Opposing Broker Number and the Contra Party Identifier fields would be populated with their default values.

Attachment A

Record Layout for Submission of Trading Information

 
Field Position Field Length Field Name/Description/Remarks Field Format Justify Picture Clause Default Value
From To
  ***This record must be the first record of the file***  
1 3 3 FILLER A LJ X(3) HDR
4 5 2 FILLER A LJ X(2) .S
6 10 5 DTRK-SYSID N LJ 9(5) 12343
11 12 2 FILLER A LJ X(2) .E
13 14 2 FILLER N LJ 9(2) 00
15 16 2 FILLER A LJ X(2) .C
17 20 4 DTRK-ORIGINATOR
Please call SIAC for assignment (212) 383-2210.		 A LJ X(4) —
21 22 2 FILLER A LJ X(2) .S
23 26 4 DTRK-SUB-ORIGINATOR Please call SIAC for assignment (212) 383-2210. A LJ X(4) —
27 27 1 FILLER A LJ X(1) B
28 33 6 DTRK-DATE
Contains submission date.		 N LJ 9(6) MMDDYY
34 34 1 FILLER A LJ X(1) B
35 59 25 DTRK-DESCRIPTION Required to identify this file. A LJ X(25) FIRM TRADING INFORMATION
60 80 21 FILLER A LJ X(21) B
1 1 1 HEADER RECORD CODE Value: Low Values OR ZERO A — X —
2 5 4 SUBMITTING BROKER NUMBER If NSCC member use NSCC clearing number.
If not a NSCC member, use clearing number assigned to you by your clearing agency.		 A–R LJ X(4) B
6 40 35 FIRM'S REQUEST NUMBER Tracking number used by the firm to record requests from an organization. A — X(35) B
41 46 6 FILE CREATION DATE Format is YYMMDD A — X(6) —
47 54 8 FILE CREATION TIME Format is HH:MM:SS A — X(8) —
55 55 1 REQUESTOR CODE Requesting Organization Identification Values: A — X —
      A = New York Stock Exchange        
      B = NYSE MKT, LLC        
      C = Chicago Stock Exchange        
      D = NASDAQ OMX        
      E = NYSE Arca        
      F = NASDAQ OMX BX, Inc.        
      G = National Stock Exchange        
      H = BATS Exchange, Inc.        
      I = International Securities Exchange        
      J = Direct Edge (EDGA Exchange and EDGX Exchange)        
      K = Chicago Board Options Exchange, C2 Options Exchange and CBSX (CBOE Stock Exchange)        
      R = FINRA        
      U = BOX Options Exchange, LLC        
      X = U.S. Securities and Exchange Commission        
      Y = BATS Y-Exchange, Inc.        
      Z = Other        
56 70 15 REQUESTING ORGANIZATION NUMBER
Number assigned by requesting organization.		 A LJ X(15) B
71 80 10 FILLER A — X(10) B
1 1 1 RECORD SEQUENCE NUMBER ONE The first record of the transaction. Value: 1 A — X —
2 5 4 SUBMITTING BROKER NUMBER Identical to Submitting Broker Number in Header Record A–R LJ X(4) —
6 9 4 OPPOSING BROKER NUMBER The NSCC clearing house number of the broker on the other side of the trade. A–R LJ X(4) B
10 21 12 CUSIP NUMBER
The cusip number assigned to the security.

Left justified since the number is nine characters at present (8+ check digit) but will expand in the future.		 A LJ X(12) B
22 29 8 TICKER SYMBOL The symbol assigned to this security. For options (pre-OSI), the OPRA option symbol (space), OPRA expiration month symbol and OPRA strike price symbol should be used. (Ex. Maytag May 20 call option series would be reported as MYG ED. This example uses six spaces in the field with a space between the OPRA symbol and the OPRA expiration month.)

Post OSI this field must contain OPTIONXX and a Record Sequence Number Six must be completed.		 A–R LJ X(8) B
30 35 6 TRADE DATE
The date this trade executed. Format is YYMMDD.		 A–R   X(6) B
36 41 6 SETTLEMENT DATE
The date this trade will settle.
Format is YYMMDD.		 A — X(6) B
42 53 12 QUANTITY
The number of shares or quantity of bonds or option contracts.		 N–R RJ 9(12) Z
54 67 14 NET AMOUNT
The proceeds of sales or cost of purchases after commissions and other charges.		 N RJ S9(12) V99 Z
68 68 1 BUY/SELL CODE
Values: 0 = Buy, 1 = Sale, 2 = Short Sale, 3 = Buy Open, 4 = Sell Open, 5 = Sell Close, 6 = Buy Close. A = Buy Cancel, B = Sell Cancel, C = Short Sale Cancel, D = Buy Open Cancel, E = Sell Open Cancel, F = Sell Close Cancel, G = Buy Close Cancel. Values 3 to 6 and D to G are for options only.		 A–R — X B
69 78 10 PRICE
The transaction price.
Format: $$$$ CCCCCC.		 N–R RJ 9(4)V(6) Z
79 79 1 EXCHANGE CODE Exchange where trade was executed. Values: A–R — X B
      A = New York Stock Exchange        
      B = NYSE MKT, LLC        
      C = Chicago Stock Exchange        
      D = NASDAQ OMX PHLX        
      E = NYSE Arca        
      F = NASDAQ OMX BX, Inc.        
      G = National Stock Exchange        
      H = BATS Exchange, Inc.        
      I = International Securities Exchange        
      J = C2 Options Exchange        
      K = Chicago Board Options Exchange        
      L = London Stock Exchange        
      M = Toronto Stock Exchange        
      N = Montreal Stock Exchange        
      O = TSX Venture Exchange        
      P = Direct Edge (EDGA Exchange)        
      Q=FINRA ADF        
      R = NASDAQ OMX/NASDAQ OMX Options Market        
      S = Over-the-Counter        
      T = Tokyo Stock Exchange        
      U = BOX Options Exchange, LLC        
      V = Direct Edge (EDGX Exchange)        
      W = CBSX (CBOE Stock Exchange)        
      X = NASDAQ OMX PSX        
      Y = BATS Y-Exchange, Inc.        
      Z = Other        
80 80 1 BROKER/DEALER CODE
Indicate if trade was done for another Broker/Dealer. Values: 0 = No; 1 = Yes		 A–R — X B
1 1 1 RECORD SEQUENCE NUMBER TWO Value: 2 A — X —
2 2 1 SOLICITED CODE
Values: 0 = No; 1 = Yes		 A–R — X B
3 4 2 STATE CODE
Standard Postal two character identification.		 A–R — X(2) B
5 14 10 ZIP CODE/COUNTRY CODE
Zip Code — five or nine character
(zip plus four)
Country code — for future use.		 A–R LJ X(10) B
15 22 8 BRANCH OFFICE/REGISTERED
REPRESENTATIVE NUMBER
Each treated as a four-character field.
Both are left justified.		 A–R LJ X(8) B
23 28 6 DATE ACCOUNT OPENED
Format is YYMMDD		 A–R — X(6) B
29 48 20 SHORT NAME FIELD
Contains last name followed by comma (or space) then as much of first name as will fit.		 A LJ X(20) B
49 78 30 EMPLOYER NAME A LJ X(30) B
79 79 1 TIN 1 INDICATOR
Values: 1 = SS#; 2 = TIN		 A–R — X B
80 80 1 TIN 2 INDICATOR
Values: 1 = SS#; 2 = TIN — for future use.		 A — X B
1 1 1 RECORD SEQUENCE NUMBER
THREE Value: 3		 A — X —
2 10 9 TIN ONE
Taxpayer Identification Number
Social Security or Tax ID Number.		 A–R LJ X(9) B
11 19 9 TIN TWO
Taxpayer Identification Number #2
Reserved for future use.		 A LJ X(9) B
20 20 1 NUMBER OF N&A LINES A — X B
21 50 30 NAME AND ADDRESS LINE ONE A–R LJ X(30) B
51 80 30 NAME AND ADDRESS LINE TWO A–R LJ X(30) B
1 1 1 RECORD SEQUENCE NUMBER FOUR Value: 4 A — X —
2 31 30 NAME AND ADDRESS LINE THREE A–R LJ X(30) B
32 61 30 NAME AND ADDRESS LINE FOUR A–R LJ X(30) B
62 62 1 TRANSACTION TYPE IDENTIFIERS
See Attachment B for current codes.		 A–R — X B
63 80 18 ACCOUNT NUMBER
Account number		 A–R LJ X(18) B
1 1 1 RECORD SEQUENCE NUMBER FIVE Value: 5 A — X(1) —
2 31 30 NAME AND ADDRESS LINE FIVE A–R LJ X(30) B
32 61 30 NAME AND ADDRESS LINE SIX A–R LJ X(30) B
62 65 4 PRIME BROKER
Clearing number of the account's prime broker.		 A–R LJ X(4) B
66 66 1 AVERAGE PRICE ACCOUNT
1= recipient of average price transaction.
2= average price account itself.		 N–R — 9(1) Z
67 71 5 DEPOSITORY INSTITUTION
IDENTIFIER
Identifying number assigned to the account by the depository institution.		 A–R LJ X(5) B
72 77 6 ORDER EXECUTION TIME

HHMMSS — Time format will be in Eastern Time and 24 hour format.		 A–R LJ — —
78 80 3 FILLER A — X B
1 1 1 RECORD SEQUENCE NUMBER SIX Value: 6 A — —  
2 9 8 DERIVATIVE SYMBOL
The symbol assigned to the derivative.		 A–R LJ — B
10 15 6 EXPIRATION DATE
The date the option expires.
Format is YYMMDD.		 A–R — — B
16 16 1 CALL/PUT INDICATOR C = Call, P = Put A–R — — B
17 24 8 STRIKE DOLLAR
The dollar amount of the strike price.		 N–R RJ — Z
25 30 6 STRIKE DECIMAL
The decimal amount of the strike price.		 N–R LJ — Z
31 80 50 FILLER A LJ — B
1 1 1 RECORD SEQUENCE NUMBER
SEVEN
Value: 7		 A — —  
2 14 13 LARGE TRADER IDENTIFICATION 1 A–R LJ — Z
15 27 13 LARGE TRADER IDENTIFICATION 2 A–R LJ — Z
28 40 13 LARGE TRADER IDENTIFICATION 3 A–R LJ — Z
41 41 1 LARGE TRADER IDENTIFICATION QUALIFIER A–R LJ — Z
42 49 8 PRIMARY PARTY IDENTIFIER

Identity of the party to the trade that is represented by the Submitting Broker of an EBS. Acceptable values include MPID, CRD or OCC Clearing Number.		 A–R LJ — B
50 57 8 CONTRA PARTY IDENTIFIER

Identity of the contra party to the trade that is represented by the Opposing Broker of an EBS. Acceptable values include MPID, CRD or OCC Clearing Number.		 A–R LJ — B
58 80 23 FILLER A LJ — B
1 1 1 TRAILER RECORD DATE
One record per submission. Must be the last record on the file. Value: High Values or "9"		 A — X —
2 17 16 TOTAL TRANSACTIONS
The total number of transactions. This total excludes Header and Trailer Records.		 N RJ 9(16) B
18 33 16 TOTAL RECORDS ON FILE
The total number of 80 byte records. This total includes Header and Trailer Records, but not the Datatrak Header Record (i.e., it does not include the first record on the file).		 N RJ 9(16) Z
34 80 47 FILLER A — X(47) B
      Field Format
A = Alphanumeric (all caps)
N = Numeric
P = Packed
B = Binary
R = Validation Required		 Default Values
B =Blanks
Z= Zero		 Justify
RJ = Right Justification of Data
LJ = Left
Justification of Data		    

Attachment B

Record Layout for Submission of Trading Information

Transaction Type Security Type
  Equity* Options
Non-Program Trading, Agency A C
Non-Index Arbitrage, Program Trading, Proprietary C  
Index Arbitrage, Program Trading, Proprietary D  
Index Arbitrage, Program Trading, Individual Investor J  
Non-Index Arbitrage, Program Trading, Individual Investor K  
Non-Program Trading, Proprietary P F
Non-Program Trading, Individual Investor I  
Non-Index Arbitrage, Program Trading, Agency Y  
Index Arbitrage, Program Trading, Agency U  
Designated Market Makers S S
Market-Maker   M
Non-Member Market-Maker/Specialist Account   N
Stock Specialist — Assignment   Y
Customer Range Account of a Broker/Dealer   B
Registered Trader G  
Error Trade Q  
Amex Option Specialist/Market Maker Trading Paired Security V  
Registered Trader Market Maker Transaction Regardless of the Clearing Number   P
Transactions cleared for a NASDAQ market maker that is affiliated with the clearing member that resulted from telephone access to the specialist. Amex Only. 3  
Transactions cleared for a member's NASDAQ market maker that is not affiliated with the clearing member that resulted from telephone access to the specialist. Amex Only. 4  
Transactions cleared for a non-member NASDAQ market maker that is not affiliated with the clearing member that resulted from telephone access to the specialist. Amex Only. 5  
Voluntary Professional   W
Joint Back Office   J

* Equity securities include those securities that trade like equities (e.g., ETFs and structured products).