[ by Howard Haykin ]

Start Date for Certain Electronic Blue Sheet Data Elements Now 5/1/13.

FINRA and the other U.S. members of the Intermarket Surveillance Group (ISG members) have extended the effective date for compliance with certain new data elements for Electronic Blue Sheets (EBS) identified in Regulatory Notice 12-36 to May 1, 2013. 

FINRA and the ISG alert member firms to new, additional updates: 

• Required fields added to EBS record layout.  The fields identified in RegNote 12-36 as modified below must be added to the EBS record layout by 11/30/12, as currently required.
  • However, the name and description of the Entering Firm Identifier and Executing Firm Identifier fields are being renamed as Primary Party Identifier and Contra Party Identifier fields, respectively, but the technical format specifications will remain the same.
  • As noted below, for EBS requests from FINRA and the other ISG members, these fields are not required to be populated until 5/1/13, and for SEC Large Trader EBS requests, these fields are not required to be populated, but at any time firms may voluntarily submit the values to the SEC and they will be accepted.
• SEC EBS Requests.  For Large Trader EBS requests from the SEC, the 11/30/12 and 5/1/13 effective dates and their respective requirements to populate the EBS remain unchanged.
• FINRA and the other ISG member EBS Requests.  For EBS requests from FINRA and other ISG members, the Order Execution Time, Primary Party Identifier and Contra Party Identifier fields are not required to be populated until 5/1/13.  Firms may voluntarily submit Large Trader 1-3 and Large Trader Qualifier values to FINRA and other ISG members and they will be accepted.

Attachment A to the November RegNote sets forth new additional modifications to the EBS record layout;  Attachment B outlines modifications to the Transaction Type Identifiers.

Discussion. FINRA and the other ISG members have extended the effective date for compliance with certain new data elements identified in Regulatory Notice 12-36 to 5/1/13, to allow broker-dealers additional time to implement changes to comply with the new requirements

The fields identified in Regulatory Notice 12-36 as modified as set forth below and in Attachment A must be added to the EBS record layout by November 30, 2012, as currently required.  However, ...

• The Entering Firm Identifier and Executing Firm Identifier fields are renamed as the Primary Party Identifier and Contra Party Identifier fields, respectively,
• The firm must identify the party to the trade that is represented by the Submitting Broker or Opposing Broker of an EBS, respectively.
• The technical format specifications for these fields will remain the same as previously announced.
• The firm may submit an MPID, CRD # or OCC Clearing # for such fields.
  • e.g. - if Firm A cleared through Firm B, Firm A’s MPID, CRD or OCC number would be provided in the Primary Party Identifier field and Firm B’s NSCC clearing number would appear in the Submitting Broker Number field.
  • e.g. - for the other side of the trade, if Firm C clears through Firm D, Firm C’s MPID, CRD or OCC number would be provided in the Contra Party Identifier field and Firm D’s NSCC clearing number would appear in the Opposing Broker Number field.

For Large Trader requests from the SEC ...

• The November 30, 2012, and May 1, 2013, effective dates and their respective requirements remain unchanged.
• By November 30, 2012, broker-dealers must be in EBS reporting compliance for the:

• Order Execution Time,
• Large Trader Identification Number 1-3, and
• Large Trader Identification Qualifier fields
• as such fields may apply to all NMS securities and for all transactions effected directly or indirectly by or through:

• Any proprietary account of a U.S. registered broker-dealer; or
• Any account used by a customer that trades through a “sponsored access” arrangement.

By May 1, 2013, all broker-dealers, regardless of limitations noted above, must be in compliance with SEC Large Trader requirements, including EBS requirements.

• The Primary Party Identifier and Contra Party Identifier fields are not required to be populated in response to SEC Large Trader EBS requests, but at any time firms may voluntarily submit the values to the SEC and they will be accepted.
• For EBS requests from FINRA and other ISG members, the Order Execution Time, Primary Party Identifier and Contra Party Identifier fields are not required to be populated until May 1, 2013. 
• Firms may voluntarily submit the values before May 1 and they will be accepted.
• Firms may also voluntarily submit Large Trader Identification Number 1-3 and Large Trader Identification Qualifier values to FINRA at any time and other ISG members and they will be accepted.
• The required EBS fields are set forth in the RegNote;  see Attachment A for details.

Remainder of Notice.   The RegNote provides additional reporting details, and it would be a disservice for us to try and summarize.  Therefore, we ask that you read the instructions yourself - simply click the link below to continue reading. 

The FAQs on the FINRA Web site will be updated from time to time - and will include updates for these changes, as applicable.

Direct questions ... re: EBS enhancements to ebsfaq@finra.org.

For further details, go to:  [FINRA Regulatory Notice 12-47].