My firm accesses certain market centers through sponsored access relationships with other FINRA members. What are the OATS reporting obligations for both members in these scenarios?
With respect to the members’ OATS reporting obligations, when two members have entered into a sponsored access agreement whereby one member sponsors the other member into a specific market center (such as a national securities exchange) by providing use of the sponsoring member’s MPID, both members have separate and distinct OATS reporting obligations. For example, if FINRA member ABCD sponsors access into a national securities exchange for FINRA member EFGH, the OATS reporting obligation for each firm would be as follows: Sponsored Member EFGH (under the MPID of EFGH) New Order Report Route Report indicating order was routed to ABCD Sponsoring Member ABCD (under the MPID of ABCD) New Order Report indicating the order was received from member EFGH Route Report indicating order was routed to a national securities exchange The OATS reporting obligations outlined above are the same regardless of the type of connection used by the sponsored member to access the applicable market center. Fo
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