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OATS for OTC Equity Securities - Foreign Securities
Raphael Goodman / Jefferies and Co., Inc.
8 Nov 2007 5:00PM ETStarting on February 4, 2008 the OATS eligible list will be expanding and member firms will need to begin capturing and reporting to OATS orders in certain foreign securities.
We have been given a list of exceptions from FINRA where there is no OATS obligation:
1. The orders are executed on a foreign exchange; or
2. The orders are executed OTC in a foreign country and reported to regulators in that foreign country.; or
3. The orders are routed via a foreign affiliate
4. The orders are routed to another member firm or exchange and that member firm or exchange routes the order to a foreign exchange for execution.
5. If the order does not execute, there is no 6620 requirement and no OATS obligation
My question relates to #4 - is there a Fix Tag that can be used to let the sending firm know that the receiving firm has routed the order abroad for execution? The problem is that the receiving firm knows that it routed the order abroad and therefore has no OATS reporting obligation, and will not create OATS. If the sending firm creates OATS, there will be a mismatch between the sending and receiving firms. Can the receiving firm pass this information back in a Fix Tag?
Thanks in advance
OATS for OTC Equity Securities - Foreign Securities
Raphael Goodman / Jefferies and Co., Inc. 8 Nov 2007 5:00PM ET
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