What impact does the executing party trade reporting structure have on the processing of regulatory transaction fees pursuant to Section 3 of Schedule A to the FINRA By-Laws (“Section 3”)?
A204.6: The executing party trade reporting structure has no impact on the processing of Section 3 fees. FINRA always bills Section 3 fees to the clearing member identified as the sell-side on the tape report and, as such, it makes no difference for billing purposes which member appears on the tape report as the reporting party and contra party. See, e.g., Member Alert: Additional Guidance Regarding the Automated Reporting of Transactions Subject to a Regulatory Transaction Fee (November 17, 2006).
