What should a member do if it executes a trade in a security that is reportable to the ORF under Rule 6622, but does not have a symbol?
A105.1: In those situations where a security does not have a valid U.S. symbol assigned, the member must promptly request that FINRA Operations assign a symbol to the security so that the member can fulfill its trade reporting obligations. Members should submit such request on the OTC Equity Symbol Request Form and must provide all requested information, including a CUSIP number for the security. If there is no symbol at the time the trade is executed, the trade should be reported to the ORF immediately upon the issuance of the symbol and be marked late, as applicable. If the trade is not reported on trade date, it should be reported on an “as/of” basis using the original execution date as the trade date. Q105.2: Security ABCD is the subject of an initial public offering (IPO) and will later be listed on the NYSE. Immediately after the distribution and before the security becomes listed on the NYSE, the security begins trading OTC. Must these trades be reported to FINRA? A105.2: Yes, t
