FINRA Clarifies OATS Reporting Requirements for Non-FINRA Members

FINRA reminded firms that reports to the Order Audit Trail System ("OATS") must include the identities of (i) U.S.-registered broker-dealers that are not FINRA members, and (ii) broker-dealers that are not registered in the U.S. but have received an identifier assigned by a Self-Regulatory Organization ("SRO").

FINRA emphasized that it is updating the OATS Reporting Technical Specifications to require that OATS reports identify any non-FINRA member broker-dealer to which an order is routed through either a central registration depository ("CRD") number or an SRO-assigned identifier. FINRA noted that it will provide a list of all acceptable CRD numbers for firms to use in order to facilitate compliance with the new requirements. The updates to the OATS Reporting Technical Specifications will be implemented on August 1, 2016, which is the effective date of the OATS amendments.