A103.1: Currently, ADF, FINRA/NASDAQ TRF and ORF offer commercial acceptance and comparison functions. See Rules 7130 (b), 7230A (b) and 7330 (b). This means that the notifying party transmits the business information and the counterparty accepts (or rejects) the business information provided by the reporting party. The parties must use the commercial acceptance and transaction function in the absence of a waiver agreement between the parties. See FAQ 200.1. In addition, ADF, FINRA/NASDAQ TRF and ORF offer a matching feature in which each party enters its own business information and the ease crosses the two reports. See Sections 7140, 7240A and 7340. See also Trade Reporting Notice 10/7/16 (Trade Match” and “Trade Acceptance” Clearing Submissions on FINRA`s Alternative Display Facility). Q205.13: Start from the same facts as faq 205.9. If the parties agree to transfer the commercial reporting obligation to BD1, can the commercial transaction and acceptance functionality of FINRA/NASDAQ TRF, ADF or ORF meet the requirement that BD2 simultaneously document the parties` agreement? In other words, if BD1 (the member representing the purchasing party) declares the trade and accepts BD2 (the member representing the seller) the commercial information entered by BD1, would this be sufficient proof of the simultaneous agreement between the parties to transfer the commercial declaration obligation to BD1? A205.12: Yes. BD1 may report on behalf of BD2 under a previously entered into waiver agreement; However, in this case, the commercial declaration obligation is not deferred to BD1.

As a result, BD2 would remain responsible for compliance with FINRA`s reporting rules and could, for example, be subject to a violation of the late commercial declaration if BD1 does not file the tape report within 10 seconds of execution. See Section 200 (Reports on behalf of another member). Model A agreements use a contract for intermediation and custody services between the client and the broker and a subcontract for custody services between the broker and the custodian bank. Unlike Model B contracts, payments range from the deposit bank to the broker and from the broker to the client. The deposit bank does not report anything unless the broker is an individual or a partnership. The broker only reports revenue streams to the client if the client is an individual. An agreement between different brokers to allow and process an investor`s trading with a single broker. Since an investor may have business relationships with multiple brokers, he or she may initiate trading with different brokers, but at the time of settlement, he or she may settle accounts with a single broker. This broker will present the clearing house trades for settlement. This agreement exists between brokers and individual investors, who can choose several brokers for trading and one broker for settlement. A clearing Member Trade Agreement (CMTA) is an agreement in which an investor can enter into derivatives trades with a limited number of different brokers, but can consolidate them later at the end of the trading day with a single broker for clearing.

Q205.12: Start from the same facts as FAQ 205.9, but in this example, the parties do not agree to postpone the commercial reporting obligation. . . .