FIF Details Recommendations on FINRA Proposed IDQS OTC Equity Security Reporting Requirements

In a supplemental Comment Letter in response to a FINRA proposed rulemaking on disclosure of order routing information, the Financial Information Forum ("FIF") offered recommendations on how execution venues can satisfy the reporting requirements for trade messages sent through, and quotes posted on, an inter-dealer quotation system ("IDQS") for OTC Equity Securities.

FIF recommended that, regardless of the entity that executes the trade, the venue for execution would be deemed to be the eligible IDQS that facilitated the transaction. FIF described "trading workflows that are available through the OTC Link ATS, and recommend[ed] how the venue for execution should be reported for these workflows in the routing reports proposed in the FINRA Rule Filing."