Does the 90-second Rule apply to OATS reporting?
No. The 90-second Rule has not changed. It only applies to trade reporting. OATS is NOT a real-time system. Although some order information must be recorded during the day, such as the date and time of order receipt, order information may be transmitted to OATS at any time, including during or after market hours. However, reports for events that occur during a particular OATS Business Day must be reported by 05:00 (5:00 a.m.) Eastern Time the following calendar day or they are marked late by FINRA.