What monitoring resources will be made available to member firms that qualify for the exclusion to the definition of reporting member?
Firms that do not meet the definition of “Reporting Member” are not required to report data to OATS. Rather, the receiving Reporting Member is required to report to OATS the receipt of an order from the sending firm and any subsequent events relating to that order. Since no data is reported by, or on behalf of the sending member under the sending member’s MPID, there is no data for the sending firm to monitor. FINRA, however, strongly encourages members that qualify for exclusion from the definition of an OATS Reporting Member to have a process in place to validate periodically that the receiving Reporting Member is reporting to OATS as required. This process may include obtaining a written statement from the receiving Reporting Member that they, to the best of their knowledge, are reporting all orders received from the sending member in compliance with the OATS Rules.
