What has FINRA updated?
The Financial Industry Regulatory AuthorityTM (FINRATM) has provided a new compliance Question and Answer related to Order Audit Trail System (OATS) and sponsored access that has been added to FINRA’s “OATS Frequently Asked Questions,” which is available on FINRA’s web site. 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 Mem