FINRA – Proposed Rule Change Relating to Granularity of Timestamps in Trade Reports Submitted to FINRA’s Equity Trade Reporting Facilities

September 18, 2020

Proposed Amendments

FINRA proposed to amend equity trade reporting rules to require members obligated to report order execution events to Central Repository per CAT Compliance Rule. To report time fields (including the time of execution) in trade reports submitted to FINRA Facility using the same timestamp granularity used to report to Central Repository. All trades that are reported to a FINRA Facility must also be reported to CAT; therefore, already subject to timestamp granularity requirements under CAT Compliance Rule.

One instance where the firm has obligation to report to FINRA Facility without also CAT reporting obligation on a trade-in Restricted Equity Security effected per Rule 144A. The firm could report to ORF in seconds or, if captured time in milliseconds, required to report in milliseconds; not required to report in increments finer than milliseconds.


On September 18, 2020, FINRA proposed rule, comments due 21 days after federal register. The implementation date of the proposed rule for TRFs and ADF no later than December 15, 2021. The implementation date of the proposed rule relating to ORF no later than December 15, 2022.

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