What is the time of receipt for a manual order called in after hours?
The OATS time of receipt for after hours orders should be the same time the firm records to satisfy its SEC Rule 17a-3(a)(6) recording obligation with respect to that order. 6. In Notice to Members 05-78, FINRA provided guidance regarding the time of receipt on orders that went through a review and release process. Specifically, in Q5 of the Question and Answer Section of the Notice, FINRA stated that the time of receipt should be the time the order is received from the customer and that the review or other release practices of a firm would not change this requirement. Is this guidance consistent with subsequent guidance from FINRA that the time of receipt for OATS reporting purposes should be the time of receipt required to be recorded pursuant to SEC Rule 17a-3? The time of receipt for OATS reporting purposes should always be the same as the time of receipt already required by SEC Rule 17a-3. Therefore, members that subject orders to a review and release process should record the tim
