My firm provides both sponsored access and direct market access to non-FINRA member clients. Is my firm responsible for any OATS reportable events associated with these clients access?
Yes. As a general matter, FINRA considers a firm to be the executing broker in any transaction where its client (either a customer or a non-NASD member broker/dealer client) is only able to effect the trade by virtue of the firm’s membership with the applicable market center. Thus, if a client would not be able to effect trades without the use of a FINRA member’s assigned MPID, that FINRA member is responsible for reporting the necessary information to OATS.
Related Questions
- My firm provides both sponsored access and direct market access to non-FINRA member clients. Is my firm responsible for any OATS reportable events associated with these clients access?
- 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?
- How can ClearBenefits help streamline the way my firm provides service to our clients?
