FINRA Streamlines Trade Reporting for Dual Broker-Dealer/Investment Advisers

"FINRA has amended its TRACE reporting requirements to permit a firm that is both a broker-dealer and an investment adviser to report allocations of specified orders to managed customer accounts in a streamlined, aggregated manner."
FINRA Regulatory Notice 25-17
"FINRA has amended its TRACE reporting requirements to permit a firm that is both a broker-dealer and an investment adviser to report allocations of specified orders to managed customer accounts in a streamlined, aggregated manner."
FINRA Regulatory Notice 25-17

FINRA amended its transaction reporting requirements to permit firms acting as both broker-dealers and investment advisers to report allocations to managed accounts using a simplified, aggregated method.

Under the new guidance, dual registrants may choose to report allocations of an aggregate order to multiple managed customer accounts as a single trade report, rather than reporting each allocation separately. FINRA said that to utilize this option, the allocations must be executed at the same price and time, and the firm must include the total number of managed accounts receiving allocations in the aggregate report.

FINRA emphasized that this streamlined reporting alternative is voluntary, allowing firms to continue reporting individual allocations if they prefer. The amendment will become effective on June 8, 2026. FINRA said it will disseminate the aggregate volume and the number of accounts involved, subject to existing transaction size caps.

In the same notice, FINRA said it is maintaining the current 15-minute reporting standard and will not proceed with a previously approved proposal to reduce the reporting timeframe to one minute. FINRA decided not to move forward with the one-minute requirement after firms raised concerns regarding the implementation of the reduced reporting time regime.

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