Trade | FINRA CAT (4.0.0-r18) | Orchimate

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Trade (MEOT)

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A Trade Event is used when the Industry Member acts as the executing broker and is required to report the trade for public dissemination purposes. When an Industry Member is not required to report the execution of a customer/client order for public dissemination purposes, with the exceptions noted below, an Order Fulfillment event must be used. See Section Order Fulfillment for more details.

Reporting Exception Codes

In general, Trade events are required to match to a TRF/ORF/ADF report. However, there are four circumstances when an MEOT would not be able to be linked to a TRF report and a Reporting Exception Code (REC) is required on a Trade event to allow the Processor to identify that there will be no link to a TRF/ORF/ADF report:

An Industry Member executes a trade between two desks or departments of the same firm, but because there is no change in beneficial ownership, no trade is reported for public dissemination. In this instance a REC of “P” should be used on the Trade event.
An Industry Member executes a trade and must report the trade via Form T. In this instance, a REC of “F” should be used on the Trade event.
A trade was executed by a non-FINRA member firm and was reported to the TRF by the FINRA member counterparty. In this instance, the non-FINRA member must populate a REC of “N” on the Trade event.
Industry Member was the contra side of the trade report which was reported to a TRF/ORF/ADF via a QSR or AGU, and was therefore unable to populate a tapeTradeID. In this instance, a REC of ‘C’ should be used on the Trade event to reflect a linkage to the related TRF/ORF/ADF report could not be made. The following rules apply when REC ‘C’ is used:
- The marketCenterID field must be populated.
- The clearingFirm and counterparty fields must be populated.
- The cancelFlag and cancelTimestamp must be populated accordingly for all trades that are reported to a TRF via a QSR or AGU and later cancelled, as the CAT would not be able to link to a related TRF cancellation.
FINRA CAT will closely monitor all uses of REC ‘C’ to ensure compliance with the above noted guidelines.

Trade Side Details

Trade events are two-sided, containing information on both sides of the trade. Exceptions requiring only one side of the Trade event to be populated are noted below. The details of each side are reported using Trade Side Details. The data type Trade Side Details is described as a list of fields in Table 49 below. Trade Side Details must contain only one orderID per side. The buyDetails must contain the orderID of the buy side of the trade and the sellDetails must contain the orderID of the sell side of the trade. If there is more than one orderID associated with one side of the trade, the Trade Side Details related to each orderID must be populated in a separate Trade Supplement event.

Internalized Trade

When an Industry Member internalizes an order by filling it from a proprietary account, the Industry Member must report the orderID on the customer/client side and the FDID and the accountHolderType of the proprietary account on the firm side. In this scenario, no orderID is required on the firm side of the Trade event.

However, if the Industry Member generates a proprietary order to facilitate the execution of the customer/client order, the Industry Member must report the orderID of both the customer/client side and the firm side of the Trade event. Refer to CAT FAQ B41 for additional information.

One-Sided Trade events

There are several exceptions which only require one side of a Trade event to be populated. These exceptions include:

Trade is executed as the result of a negotiation between two Industry Members.
Order is routed by a FINRA Member to a non-FINRA member, and the FINRA Member has the obligation to submit a media trade report to a TRF/ADF/ORF.
Order is routed by an Industry Member to a foreign broker-dealer, and the foreign broker-dealer executes the order at a net price, creating a media trade reporting obligation in the United States.

In these scenarios, each party that is required to report a Trade event to CAT must populate the sideDetailsInd indicating which side of the trade the Industry Member was associated with, and which Trade Side Details will be populated in the Trade event.

Cancelled Trades

In accordance with CAT FAQ E25, the cancelFlag must be set to true only in instances when a trade is cancelled because the trade report is rejected by the TRF/ORF or ADF. For all instances where a trade is reported to, and accepted by, the TRF/ORF or ADF, including those that are cancelled or busted in the trade reporting data, the cancelFlag must be set to false. Refer to CAT FAQ E29 and CAT FAQ E30 for additional information.

Field	Name	Type	Req'd	Comments
2	actionType	actionTypeCodeSet	Y	Indicates whether the event is a new event, firm initiated correction or a repair of a CAT error.
38	errorROEID	Unsigned		Required when actionType is ‘RPR’. Must be blank when actionType is ‘NEW’.
44	firmROEID	Text	Y	An identifier assigned to the record by the reporting firm. Formatted as _ Must be unique for the Event Date and CAT Reporter IMID.
131	type	typeCodeSet	Y	MEOT
22	CATReporterIMID	CATReporterIMID		The SRO-assigned identifier that an Industry Member uses to report to CAT. If populated, must equal the CATReporterIMID in the filename.
128	tradeKeyDate	Timestamp	Y	The date and time the tradeID was assigned.
127	tradeID	Text	Y	Unique ID assigned to this execution by the Industry Member. This ID will be used in subsequent events when a specific trade needs to be identified. The combination of date, CATReporterIMID, symbol, and tradeID must be unique.
123	symbol	Symbol	Y	The symbol of the stock in the symbology of the primary listing exchange or FINRA for OTC Equity Securities.
39	eventTimestamp	Timestamp	Y	The date/time at which the trade was executed. If manualFlag is ‘true’, timestamp must be reported to seconds. If manualFlag is ‘false’, timestamp must be reported to milliseconds or a finer increment up to nanoseconds.
56	manualFlag	manualFlagCodeSet	Y	Must be marked as ‘true’ if this is a manual execution.
37	electronicTimestamp	Timestamp		The time at which the event is systematized.
19	cancelFlag	cancelFlagCodeSet	Y	Must be marked as ‘true’ if the execution is cancelled and was not reported to the TRF/ADF/ORF.
20	cancelTimestamp	Timestamp		When cancelFlag is ‘true’, the time at which the execution was cancelled. If manualFlag is ‘true’, timestamp must be reported to seconds. If manualFlag is ‘false’, timestamp must be reported to milliseconds or a finer increment up to nanoseconds.
108	retiredFieldPosition	Text		Field position is retired and must remain blank.
108001	retiredFieldPosition1	Text		Field position is retired and must remain blank.
96	quantity	RealQuantity	Y	Quantity of the trade.
84	price	Price	Y	The execution price of the trade. Must be greater than or equal to zero.
21	capacity	capacityCodeSet	Y	The capacity in which the Industry Member acted.
124	tapeTradeID	Text		The unique identifier reported by the Industry Member to the TRF/ADF/ORF based on the reporting specifications of the specific facility, required when the ID was supplied to a transaction reporting system: Compliance ID in ORF and ADF Branch Sequence Number in FINRA/NQ TRF FINRA Compliance Number in FINRA/NYSE TRF Must be unique per combination of Event Date, CATReporterIMID, marketCenterID and symbol. The tapeTradeID may link to either the reporting side or the contra-side of the media tape report. When the reportingExceptionCode field is blank, the tapeTradeID field must be populated. When the reportingExceptionCode field is populated, the tapeTradeID field must be blank.
59	marketCenterID	marketCenterIDCodeSet		The national securities exchange or transaction reporting system operated by FINRA where the trade was reported. When the marketCenterID field is blank, the reportingExceptionCode must be populated with a value other than ‘C’. When the marketCenterID field is populated, the reportingExceptionCode field must be blank, or must be populated with a value of ‘C’.
121	sideDetailsInd	sideDetailsIndCodeSet	Y	Identifies if a Trade event is one sided, and which side of the trade the Industry Member is populating in the Trade Side Details. When sideDetailsInd is ‘BUY’, only the buyDetails are populated. When sideDetailsInd is ‘SELL’, only the sellDetails are populated.
	buyDetails	buyDetails		See Table 49: Trade Side Details below. Applicable if there is only one orderID associated with this side of the trade. If there is more than one orderID, must be populated in separate MEOTS events.
	sellDetails	sellDetails		See Table 49: Trade Side Details below. Applicable if there is only one orderID associated with this side of the trade. If there is more than one orderID, must be populated in separate MEOTS events.
104	reportingExceptionCode	reportingExceptionCodeCodeSet		Indicates the reason that a unique identifier (e.g., Branch Sequence Number, Compliance ID) was not supplied to a transaction reporting system. Must be provided if the execution is not reported to a FINRA transaction reporting system. When the tapeTradeID field is blank, the reportingExceptionCode field must be populated. When the tapeTradeID field is populated, the reportingExceptionCode field must be blank. When the marketCenterID field is blank, the reportingExceptionCode field must be populated. When the marketCenterID field is populated, the reportingExceptionCode must be blank.
117	seqNum	Alphanumeric		The sequence number assigned to the Reportable Event by the ATS’s matching engine. Any alphanumeric not containing a delimiter.
65	nbbPrice	Price		The NBBO at the moment the trade occurred. Prices are required, quantities are optional. When provided, must be greater than or equal to zero. If no price or quantity, fields must be populated with value of ‘0’.
66	nbbQty	WholeQuantity		The NBBO at the moment the trade occurred. Prices are required, quantities are optional. When provided, must be greater than or equal to zero. If no price or quantity, fields must be populated with value of ‘0’.
67	nboPrice	Price		The NBBO at the moment the trade occurred. Prices are required, quantities are optional. When provided, must be greater than or equal to zero. If no price or quantity, fields must be populated with value of ‘0’.
68	nboQty	WholeQuantity		The NBBO at the moment the trade occurred. Prices are required, quantities are optional. When provided, must be greater than or equal to zero. If no price or quantity, fields must be populated with value of ‘0’.
63	nbboSource	nbboSourceCodeSet		Source of the NBBO Data Used. If nbboSource is ‘NA’, NBBO price and quantity fields must be populated with a value of ‘0’ and the nbboTimestamp must be blank.
64	nbboTimestamp	Timestamp		The date/time at which the NBBO was referenced upon the receipt of the order. Must be blank if nbboSource is ‘NA’.
108002	retiredFieldPosition2	Text		Field position is retired and must remain blank.
24	clearingFirm	Unsigned		The clearing number of the Industry Member’s clearing firm. Required when the reportingExceptionCode is ‘C’.
26	counterparty	IndustryMemberID		The counterparty to the trade. Required when the reportingExceptionCode is ‘C’.
62	multiLegInd	multiLegIndCodeSet	Y	Indicates when the execution is related to a multi-leg order event. Refer to Section 5.2 for additional guidance.
48	infoBarrierID	Text		Specifies the identifier of the information barrier in place for a trading unit that will meet the criteria of the “no-knowledge” exception in FINRA Rule 5320.02. Any alphanumeric not containing a delimiter.

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Trade (MEOT)