FINRA members are reminded to submit their last sale reports of OTC equity transactions on Form T (for which e-submission is not possible), as-soon-as-practicable.  And FINRA tells us help is on the way - electronic submission of Form T.  Firms will be required to submit Form T in accordance with this new process no later than 7/5/11.  FINRA staff contacts:

Direct your questions to either Dave Chapman, Market Reg Director -  240.386.4995, or Office of General Counsel - 202.728.8071.

Under FINRA trade reporting rules, ... whenever e-submission to a FINRA Facility is not possible, firms must report last sale reports to Market Regulation on Form T ASAP - e.g., when the ticker symbol for the security is no longer available, or the transaction occurred on a holiday or weekend, or the transaction was executed more than 365 days prior to the submission date.  Transactions that
can be reported to a FINRA Facility, whether on trade date or on a subsequent date in an “as/of” basis (T+N), must not be reported on Form T.

Form T Going Electric, 7/5.   Electronic submission of the Form T begins in July, and will process through FINRA’s Firm Gateway.  Firms no longer will be able to submit the Form T via email.  Through the Firm Gateway, in addition to creating and submitting Form T filings electronically, firms will be able to view, edit and delete draft filings, as well as view previously submitted filings.  Firms will be required to continue providing trade details on an Excel spreadsheet as part of the Form T submission. 

Firms can begin the new submission process as early as Monday, 6/6/11 - even though it's not required until 7/5.  When using this new process, users must have a FINRA User ID and password.  The Super Account Administrator (SAA) at each firm has the ability to assign user access rights to Form T for themselves and employees at their respective firms.  A firm’s SAA will be able to assist with establishing a new FINRA user ID and password, or using an existing user ID and password, to access the form. Users should contact their firm’s SAA for access requests. SAAs may contact the FINRA Help Desk at (800) 321-6273 with questions. 

For further details, go to:   [FINRA Trade Reporting Notice, 6/3/11]