Firm X acts both as an exchange specialist and as an OTC market maker. How should Firm X report under the Rule?
Firm X operates as two separate market centers and must report separately (with a separate market center identification code) on trading in each venue. The definitions in paragraph (a) of the Rule set out the different types of market centers that must report under the Rule. The term “market center” is defined in paragraph (a)(14) as “any exchange market maker, OTC market maker, alternative trading system, national securities exchange, or national securities association.” An “exchange market maker” is defined in paragraph (a)(9) of the Rule as “any member of a national securities exchange that is registered as a specialist or market maker pursuant to the rules of such exchange.” An “OTC market maker” is defined in paragraph (a)(18) of the Rule as “any dealer that holds itself out as being willing to buy from and sell to its customers, or others, in the United States, a national market system security for its own account on a regular or continuous basis otherwise than on a national secu
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