How should Exchange for Physicals (“EFP”) transactions be reported to OATS?
Like a negotiated transaction, both the buyer and seller of the reportable security in an EFP transaction would have an obligation to report New Order and Execution Reports (or Combined Order/Execution Reports) at the time the transaction occurs. The New Order Report should contain the Special Handling Code of E.W to identify it as an EFP. Finally, if the contra party on the trade report is not able to enter a branch/sequence number due to system constraints, they may use a Reporting Exception Code of M.
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