My firm operates a convertible bond department. Does my firm have to report information to OATS about orders in convertible bonds?
The OATS Rules apply to orders in Nasdaq Stock Market equity securities. Section 3(a)(11) of the Securities and Exchange Act of 1934 and SEC Rule 240.3a11-1 define “equity security” as any security convertible into stock or a similar security. Convertible bonds can be converted into equity securities. Therefore, orders for convertible bonds listed on Nasdaq are subject to OATS reporting.
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