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My firm receives and handles orders in Nasdaq and OTC listed securities, however, all clearing activities are handled by another firm. Does my firm have to report to OATS?

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My firm receives and handles orders in Nasdaq and OTC listed securities, however, all clearing activities are handled by another firm. Does my firm have to report to OATS?

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You are required to report to OATS all of your transactions in Nasdaq and OTC listed securities. However, if you have an arrangement with a clearing firm, it is possible that the clearing firm will report order information on your behalf. (NOTE: You must be in the position to provide your clearing firm with information required to be reported under the rules.) The agreement to use another firm or a third party, such as a clearing firm, must be arranged by your firm, evidenced in writing, and retained by both parties to the agreement. The agreement must specify the respective functions and responsibilities of each party. Do NOT assume that any third party will perform reporting on behalf of your firm.

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