FINRA Provides Temporary Exception for Qualifying Overnight Transactions

FINRA provided its members with a limited, temporary exception for reporting certain qualifying overnight transactions executed before 8:00 a.m. Eastern Time.

Beginning March 30, 2026, Trade Reporting Facility ("TRF") operating hours will begin at 4:00 a.m. Eastern Time, which would normally require transactions executed between 4:00 a.m. and 8:00 p.m. to be reported within ten seconds of execution. In response to operational concerns raised by members regarding this early opening, FINRA adopted a temporary exception that allows qualifying overnight transactions executed before 8:00 a.m. to be reported by 8:15 a.m. on the trade date, or by 8:15 a.m. on the following business day if executed between 8:00 p.m. and midnight or on a non-business day.

To be considered a "qualifying overnight transaction," the trade must be "appended with the .W modifier," which denotes a special pricing formula or average weighting. Additionally, the transaction must either result from an overnight batch process or involve an exchange-traded fund trade agreed upon during normal hours but executed based on a "net asset value" published after the TRF closed.

This temporary reporting exception becomes effective on March 30, 2026, coinciding with the extended TRF operating hours. The exception will expire on December 31, 2027, or upon the effective date of any further extensions to TRF operating hours, whichever occurs first.

The notice and its temporary exception directly relate to amendments to FINRA Rule 6380A and Rule 6380B ("Transaction Reporting"), which govern transaction reporting for the FINRA/Nasdaq TRFs and the FINRA/NYSE TRF, respectively.