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13-38 FINRA and ISG Extend Effective Date for Certain Electronic Blue Sheet Data Elements; Effective Date: May 1, 2014

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Regulatory Notice
Notice Type

Guidance
Suggested Routing

Compliance
Legal
Operations
Senior Management
Key Topics

Blue Sheets
Referenced Rules & Notices

FINRA Rule 8211
FINRA Rule 8213
Notice to Members 05-58
Regulatory Notice 11-56
Regulatory Notice 12-36
Regulatory Notice 12-47
Regulatory Notice 13-16
SEA Rule 13h-1

Executive Summary

FINRA and the other U.S. members of the Intermarket Surveillance Group (ISG members)1 have extended the effective date for compliance with certain new data elements for Electronic Blue Sheets (EBS) identified in Regulatory Notice 13-16 to May 1, 2014. FINRA and the other ISG members have also extended the effective date for compliance with certain other data elements to be consistent with the exemptive relief provided by the SEC, which extended the compliance date for certain broker-dealer recordkeeping and reporting requirements of SEA Rule 13h-1 (Large Trader Rule) from November 1, 2013 to November 1, 20152.

Attachment A to this Notice sets forth the EBS record layout, which, except for minor modifications noted below, remains unchanged from the version published in Regulatory Notice 13-16. Attachment B to this Notice outlines the Transaction Type Identifiers, which, except for minor modifications noted below, remains unchanged from the version published in Regulatory Notice 13-16.

Questions concerning the EBS enhancements should be directed to ebsfaq@finra.org.

Discussion

FINRA and the other ISG members have extended the effective date for compliance with certain new data elements for EBS identified in Regulatory Notice 13-16 to May 1, 2014. Specifically, for EBS requests from FINRA and other ISG members, the Primary Party Identifier and Contra Party Identifier fields identified in Regulatory Notice 13-16 are unchanged and the effective date for compliance has been extended to May 1, 2014, to allow broker-dealers additional time to implement changes to comply with the new requirements. The fields are reiterated below and in Attachment A to this Notice. Firms may voluntarily submit the values for Primary Party Identifier and Contra Party Identifier fields before May 1, 2014, and they will be accepted. For conventional EBS requests (not related to the Large Trader Rule), firms must provide the Order Execution Time in a similar manner to the SEC's Phase One and Phase Two requirements described in the SEC Extension Order and as described in more detail below; and the effective date for compliance has been extended to May 1, 2014. Firms may also voluntarily submit Large Trader Identification Number 1-3 and Large Trader Identification Qualifier values to FINRA and other ISG members at any time and they will be accepted.

FINRA and the other ISG members have also extended the effective date for compliance with certain data elements to be consistent with the exemptive relief provided by the SEC, which extended the compliance date for certain broker-dealer recordkeeping and reporting requirements of the Large Trader Rule from November 1, 2013, to November 1, 2015. The SEC has grouped the Large Trader Rule into three phases for purposes of implementation.

• Phase One required clearing broker-dealers for large traders to keep records of and report, upon the SEC's request, specified data concerning (1) proprietary trades by large traders that are U.S. registered broker-dealers; and (2) transactions effected by large traders through a sponsored access arrangement.3 Transaction data include both the large trader identification number (LTID) and execution time. The compliance date for Phase One was November 30, 2012.
• Phase Two extends the recordkeeping and reporting requirements for clearing broker-dealers to transactions effected pursuant to a direct market access (DMA) arrangement.4 As with Phase One, this requires clearing broker-dealers to report Transaction Data that includes both LTID and execution time for DMA arrangements. Phase Two also include the prime broker or other carrying broker-dealer that carries an account for a Large Trader. These entities will have to report Transaction Data other than execution time, e.g., the applicable LTID. The compliance date for Phase Two is November 1, 2013.

In addition, the recordkeeping and reporting requirements with respect to Unidentified Large Traders, and the related monitoring safe harbor provided by SEA Rule 13h-1(f), will apply to broker-dealers that carry an account for a large trader as of November 1, 2013.
• The remaining types of large traders and the transactions not covered by Phases One and Two are covered by Phase Three. Phase Three will therefore apply to all other broker-dealers subject to the recordkeeping and reporting requirements of the Rule (i.e., broker-dealers that are large traders but do not self-clear, and broker-dealers effecting transactions directly or indirectly for a large trader where a non-broker-dealer carries the account for the large trader). The compliance date for Phase Three is November 1, 2015.

As set forth above, by November 1, 2013, broker-dealers must be in EBS reporting compliance for the Order Execution Time, Large Trader Identification Number 1-3 and Large Trader Identification Qualifier fields as outlined in Phase Two of the recordkeeping, reporting and monitoring requirements of SEA Rule 13h-1. Additionally, by November 1, 2015, broker-dealers must be in EBS reporting compliance for the Order Execution Time, Large Trader Identification Number 1-3 and Large Trader Identification Qualifier fields as outlined in Phase Three of the recordkeeping, reporting and monitoring requirements of SEA Rule 13h-1. The Primary Party Identifier and Contra Party Identifier fields are not required to be populated in response to SEC Large Trader EBS requests, but at any time firms may voluntarily submit the values to the SEC and they will be accepted.

The required EBS fields are set forth below and are unchanged from Regulatory Notice 13-16. Also see Attachment A for details.

Order Execution Time, Record Sequence Number Five, Field Position 72 to 77

Firms should use this record to submit the order execution time in 24-hour format and in Eastern Time formatted as HHMMSS. This information is not limited to the blue sheet transactions relating to the SEC Large Trader Reporting Rule (SEA Rule 13h-1). Please note that all firms must synchronize their time clocks to the atomic clock to maintain an accurate audit trail in connection to the reported execution time.

Large Trader Identification Number 1, Record Sequence Number Seven, Field Position 2 to 14

Firms should use this record to submit the Large Trader Identification Number. This information is requested under the approved SEC Large Trader Reporting Rule (SEA Rule 13h-1) requirements.

Large Trader Identification Number 2, Record Sequence Number Seven, Field Position 15 to 27

Firms should use this record to submit the Large Trader Identification Number. This information is requested under the approved SEC Large Trader Reporting Rule (SEA Rule 13h-1) requirements.

Large Trader Identification Number 3, Record Sequence Number Seven, Field Position 28 to 40

Firms should use this record to submit the Large Trader Identification Number. This information is requested under the approved SEC Large Trader Reporting Rule (SEA Rule 13h-1) requirements.

Large Trader Identification Qualifier, Record Sequence Number Seven, Field Position 41

Firms should use this record to submit the Large Trader Identification Qualifier. If more than three LTIDs exist for a transaction, then firms should mark the field "Y" for Yes. Otherwise it should be marked "N" for No. This information is requested under the approved SEC Large Trader Reporting Rule (SEA Rule 13h-1) requirements.

Primary Party Identifier, Record Sequence Number Seven, Field Positions 42 to 49

Firms should use this record to submit the Primary Party Identifier, which provides the identity of the party to the trade that is represented by the Submitting Broker of an EBS. The firm may submit a Market Participant Identifier, Central Registration Depository Number or Option Clearing Corporation Clearing Number for this field. Please note that the Primary Party Identifier field replaces the previous Entering Firm Identifier field.

Contra Party Identifier, Record Sequence Number Seven, Field Positions 50 to 57

Firms should use this record to submit the Contra Party Identifier, which provides the identity of the contra party to the trade that is represented by the Opposing Broker of an EBS, if applicable. The firm may submit a Market Participant Identifier, Central Registration Depository Number or Option Clearing Corporation Clearing Number for this field. Please note that the Contra Party Identifier field replaces the previous Executing Firm Identifier field.

Consistent with Regulatory Notice 13-16, the Employer SIC Code field has been withdrawn as an EBS requirement.

The following modifications were made to Attachment A of this Notice:

• For the Requestor Code field, the value "I" was updated to include ISE Gemini.
• For the Exchange Code field, the value "1" was added to represent ISE Gemini.

The following modifications were made to Attachment B of this Notice:

• For equity securities, the values of "3", "4", "5", "G" and "V" were deleted.

Broker-dealers are reminded that failure to properly fill out the EBS fields is a violation of FINRA Rule 8211 or 8213.

Blue Sheet Submission Methodology

Currently, EBS requests are made under specific security symbols and option symbology. As noted in Regulatory Notice 13-16, firms will be required to submit EBS, when requested, using three additional formats:

• account number and date;
• account number, symbol and date; or
• date range and Primary Party Identifier.

Compliance with this requirement is similarly extended to May 1, 2014. As outlined in Regulatory Notice 13-16, the request by account number would require firms to identify the account number of a specific account at a firm, e.g. John Doe at CC Clearing Co. The request would cover all transactions under the John Doe account number at CC Clearing Co. To reduce data submission size, an EBS request may also ask for a specific symbol and date in connection with the account number. Additionally, EBS requests may be made for a specific review period under a primary party identifier. This request would require a firm to identify a clearing firm client's blue sheets for a set number of days, weeks or months, e.g., correspondent firm ABC for the month of January 2011.

Additionally, in response to a request from the SEC for large trader transaction records, broker-dealers must be prepared to submit blue sheet data, when requested, by large trader status, including LTID number(s) as outlined in Phase One and Two of the recordkeeping, reporting and monitoring requirements of SEA Rule 13h-1.

Blue Sheet Testing

FINRA's customer test website is available for firms to test whether the field format of their enhanced blue sheets data file is consistent with the EBS record layout before submitting it to production. The test website will not test whether the inputted values are complete or accurate. Firms that already have entitlement to FINRA's Regulation Filing Application can proceed with testing their EBS modifications by submitting their test data to https:// regfilingtest.finra.org. To access the customer test website, firms should enter the same user ID and password that they use to access the production website. Firms that do not have entitlement to FINRA's Regulation Filing Application should contact (800) 321-6273.

The Securities Industry Automation Corporation (SIAC) is also available to receive blue sheet test files. Firms can obtain initial testing instructions from SIAC by contacting Eugene Chernovetsky at (212) 656-2867 or echernovetsky@nyx.com or David Savage at (212) 383-3410 or dsavage@nyx.com.

Frequently Asked Questions

FINRA provides answers to frequently asked questions (FAQ) on its website. The FAQs will be updated from time to time. Please see FINRA's website for the most recent version. Questions concerning the EBS enhancements should be directed to ebsfaq@finra.org.


1 The U.S. members of the ISG include the following exchanges and self-regulatory organizations (SROs): BATS Exchange, Inc., BATS Y-Exchange, Inc., Chicago Board Options Exchange, Inc., C2 Options Exchange, Inc., CBOE Stock Exchange, LLC, Chicago Stock Exchange, Inc., EDGA Exchange, Inc., EDGX Exchange, Inc., FINRA, International Securities Exchange, LLC, The NASDAQ Stock Market LLC, NASDAQ OMX BX, Inc., NASDAQ OMX PHLX LLC, National Stock Exchange, Inc., New York Stock Exchange, LLC, NYSE MKT, LLC, NYSE Area, Inc., BOX Options Exchange, LLC, Miami International Securities Exchange, LLC and ISE Gemini.

2 The SEC issued an order temporarily exempting certain broker-dealers and certain transactions from recordkeeping and reporting requirements of the Large Trader Rule. See Securities Exchange Release No. 70150 (August 8, 2013), 78 FR 49556 (August 14, 2013) for further details (SEC Extension Order).

3 A sponsored access arrangement is defined as one "where a broker-dealer permits a customer to enter orders into a trading center without using the broker-dealer's trading system (i.e., using the customer's own technology or that of a third party provider)." See Extension Order, supra note 3 at 49557.

4 A direct market access arrangement is defined as "an arrangement whereby a broker-dealer permits customers to enter orders into a trading center but such orders flow through the broker-dealer's trading systems prior to reaching the trading center." See Extension Order, supra note 2 at 49560. In that order, the SEC noted that direct market access arrangements subject to recordkeeping and reporting in Phase Two, would include, for example, those where the large trader customer enters individual orders manually or through an algorithm under its control, but those orders flow through the broker-dealer's systems prior to reaching the trading center. Phase Two would not include, however, large trader customers that delegate to the broker-dealer the discretion to determine the price, size, timing, or routing of individual orders. Id.


Attachment A

Record Layout for Submission of Trading Information

Field Position Field Length Field Name/Description/Remarks Field Format Justify Picture Clause Default Value
From To
  ***This record must be the first record of the file***  
1 3 3 FILLER A LJ X(3) HDR
4 5 2 FILLER A LJ X(2) .S
6 10 5 DTRK-SYSID N LJ 9(5) 12343
11 12 2 FILLER A LJ X(2) .E
13 14 2 FILLER N LJ 9(2) 00
15 16 2 FILLER A LJ X(2) .C
17 20 4 DTRK-ORIGINATOR
Please call SIAC for assignment
(212) 383-2210.
A LJ X(4)
21 22 2 FILLER A LJ X(2) .S
23 26 4 DTRK-SUB-ORIGINATOR
Please call SIAC for assignment
(212) 383-2210.
A LJ X(4)
27 27 1 FILLER A LJ X(1) B
28 33 6 DTRK-DATE
Contains submission date.
N LJ 9(6) MMDDYY
34 34 1 FILLER A LJ X(1) B
35 59 25 DTRK-DESCRIPTION
Required to identify this file.
A LJ X(25) FIRM TRADING INFORMATION
60 80 21 FILLER A LJ X(21) B
1 1 1 HEADER RECORD CODE
Value: Low Values OR ZERO
A X
2 5 4 SUBMITTING BROKER NUMBER
If NSCC member use NSCC clearing
number.

If not a NSCC member, use clearing
number assigned to you by your
clearing agency.
A-R LJ X(4) B
6 40 35 FIRM'S REQUEST NUMBER
Tracking number used by the
firm to record requests from an
organization.
A X(35) B
41 46 6 FILE CREATION DATE
Format is YYMMDD
A X(6)
47 54 8 FILE CREATION TIME
Format is HH:MM:SS
A X(8)
55 55 1 REQUESTOR CODE
Requesting Organization
Identification Values:
A X
      A = New York Stock Exchange        
      B = NYSE MKT, LLC        
      C = Chicago Stock Exchange        
      D = NASDAQ OMX        
      E = NYSE Arca        
      F = NASDAQ OMX BX, Inc.        
      G = National Stock Exchange        
      H = BATS Exchange, Inc.        
      I = International Securities
Exchange and ISE Gemini
       
      J = Direct Edge (EDGA Exchange
and EDGX Exchange)
       
      K = Chicago Board Options
Exchange, C2 Options Exchange
and CBSX (CBOE Stock Exchange)
       
      R = FINRA        
      U = BOX Options Exchange, LLC        
      X = U.S. Securities and Exchange
Commission
       
      Y = BATS Y-Exchange, Inc.        
      7 = Miami International Securities
Exchange
       
56 70 15 REQUESTING ORGANIZATION
NUMBER

Number assigned by requesting
organization.
A LJ X(15) B
71 80 10 FILLER A X(10) B
1 1 1 RECORD SEQUENCE NUMBER ONE
The first record of the transaction.
Value: 1
A X
2 5 4 SUBMITTING BROKER NUMBER
Identical to Submitting Broker
Number in Header Record
A-R LJ X(4)
6 9 4 OPPOSING BROKER NUMBER
The NSCC clearing house number
of the broker on the other side of
the trade.
A-R LJ X(4) B
10 21 12 CUSIP NUMBER
The cusip number assigned to
the security.

Left justified since the number
is nine characters at present
(8+ check digit) but will expand
in the future.
A LJ X(12) B
22 29 8 TICKER SYMBOL
The symbol assigned to this
security. For options (pre-OSI), the
OPRA option symbol (space), OPRA
expiration month symbol and OPRA
strike price symbol should be used.
(Ex. Maytag May 20 call option
series would be reported as MYG
ED. This example uses six spaces
in the field with a space between
the OPRA symbol and the OPRA
expiration month.)

Post OSI this field must contain
OPTIONXX and a Record Sequence
Number Six must be completed.
A-R LJ X(8) B
30 35 6 TRADE DATE
The date this trade executed.
Format is YYMMDD.
A-R X(6) B
36 41 6 SETTLEMENT DATE
The date this trade will settle.
Format is YYMMDD.
A X(6) B
42 53 12 QUANTITY
The number of shares or quantity
of bonds or option contracts.
N-R RJ 9(12) Z
54 67 14 NET AMOUNT
The proceeds of sales or cost of
purchases after commissions and
other charges.
N RJ S9(12) V99 Z
68 68 1 BUY/SELL CODE
Values: 0 = Buy, 1 = Sale, 2 = Short
Sale, 3 = Buy Open, 4 = Sell Open,
5 = Sell Close, 6 = Buy Close. A = Buy
Cancel, B = Sell Cancel, C = Short
Sale Cancel, D = Buy Open Cancel,
E = Sell Open Cancel, F = Sell Close
Cancel, G = Buy Close Cancel.
Values 3 to 6 and D to G are for
options only.
A-R X B
69 78 10 PRICE
The transaction price.
Format: $$$$ CCCCCC.
N-R RJ 9(4)V(6) Z
79 79 1 EXCHANGE CODE
Exchange where trade was
executed. Values:
A-R X B
      A = New York Stock Exchange        
      B = NYSE MKT, LLC        
      C = Chicago Stock Exchange        
      D = NASDAQ OMX PHLX        
      E = NYSE Arca        
      F = NASDAQ OMX BX, Inc.        
      G = National Stock Exchange        
      H = BATS Exchange, Inc.        
      I = International Securities Exchange        
      J = C2 Options Exchange        
      K = Chicago Board Options
Exchange
       
      L = London Stock Exchange        
      M = Toronto Stock Exchange        
      N = Montreal Stock Exchange        
      O = TSX Venture Exchange        
      P = Direct Edge (EDGA Exchange)        
      Q=FINRA ADF        
      R = NASDAQ OMX/NASDAQ OMX
Options Market
       
      S = Over-the-Counter        
      T = Tokyo Stock Exchange        
      U = BOX Options Exchange, LLC        
      V = Direct Edge (EDGX Exchange)        
      W = CBSX (CBOE Stock Exchange)        
      X = NASDAQ OMX PSX        
      Y = BATS Y-Exchange, Inc.        
      Z = Other        
      1 = ISE Gemini        
      7 = Miami International Securities
Exchange
       
80 80 1 BROKER/DEALER
CODE Indicate if trade was done for
another Broker/Dealer.
Values: 0 = No; 1 = Yes
A-R X B
1 1 1 RECORD SEQUENCE NUMBER TWO
Value: 2
A X
2 2 1 SOLICITED CODE
Values: 0 = No; 1 = Yes
A-R X B
3 4 2 STATE CODE
Standard Postal two character
identification.
A-R X(2) B
5 14 10 ZIP CODE/COUNTRY CODE
Zip Code—five or nine character
(zip plus four)
Country code—for future use.
A-R LJ X(10) B
15 22 8 BRANCH OFFICE/REGISTERED
REPRESENTATIVE NUMBER
Each treated as a four-character
field.
Both are left justified.
A-R LJ X(8) B
23 28 6 DATE ACCOUNT OPENED
Format is YYMMDD
A-R X(6) B
29 48 20 SHORT NAME FIELD
Contains last name followed by
comma (or space) then as much
of first name as will fit.
A LJ X(20) B
49 78 30 EMPLOYER NAME A LJ X(30) B
79 79 1 TIN 1 INDICATOR
Values: 1 = SS#; 2 = TIN
A-R X B
80 80 1 TIN 2 INDICATOR
Values: 1 = SS#; 2 = TIN—for
future use.
A X B
1 1 1 RECORD SEQUENCE NUMBER
THREE Value: 3
A X
2 10 9 TIN ONE
Taxpayer Identification Number
Social Security or Tax ID Number.
A-R LJ X(9) B
11 19 9 TIN TWO
Taxpayer Identification Number #2
Reserved for future use.
A LJ X(9) B
20 20 1 NUMBER OF N&A LINES A X B
21 50 30 NAME AND ADDRESS LINE ONE A-R LJ X(30) B
51 80 30 NAME AND ADDRESS LINE TWO A-R LJ X(30) B
1 1 1 RECORD SEQUENCE NUMBER FOUR
Value: 4
A X
2 31 30 NAME AND ADDRESS LINE THREE A-R LJ X(30) B
32 61 30 NAME AND ADDRESS LINE FOUR A-R LJ X(30) B
62 62 1 TRANSACTION TYPE IDENTIFIERS
See Attachment B for current codes.
A-R X B
63 80 18 ACCOUNT NUMBER
Account number
A-R LJ X(18) B
1 1 1 RECORD SEQUENCE NUMBER FIVE
Value: 5
A X(1)
2 31 30 NAME AND ADDRESS LINE FIVE A-R LJ X(30) B
32 61 30 NAME AND ADDRESS LINE SIX A-R LJ X(30) B
62 65 4 PRIME BROKER
Clearing number of the account's
prime broker.
A-R LJ X(4) B
66 66 1 AVERAGE PRICE ACCOUNT
1= recipient of average price
transaction.
2= average price account itself.
N-R 9(1) Z
67 71 5 DEPOSITORY INSTITUTION
IDENTIFIER
Identifying number assigned to
the account by the depository
institution.
A-R LJ X(5) B
72 77 6 ORDER EXECUTION TIME
HHMMSS—Time format will be in
Eastern Time and 24 hour format.
A-R LJ
78 80 3 FILLER A X B
1 1 1 RECORD SEQUENCE NUMBER SIX
Value: 6
A  
2 9 8 DERIVATIVE SYMBOL
The symbol assigned to the
derivative.
A-R LJ B
10 15 6 EXPIRATION DATE
The date the option expires.
Format is YYMMDD.
A-R B
16 16 1 CALL/PUT INDICATOR
C = Call, P = Put
A-R B
17 24 8 STRIKE DOLLAR
The dollar amount of the strike
price.
N-R RJ Z
25 30 6 STRIKE DECIMAL
The decimal amount of the strike
price.
N-R LJ Z
31 80 50 FILLER A LJ B
1 1 1 RECORD SEQUENCE NUMBER
SEVEN
Value: 7
A  
2 14 13 LARGE TRADER IDENTIFICATION 1 A-R LJ Z
15 27 13 LARGE TRADER IDENTIFICATION 2 A-R LJ Z
28 40 13 LARGE TRADER IDENTIFICATION 3 A-R LJ Z
41 41 1 LARGE TRADER IDENTIFICATION
QUALIFIER
A-R LJ Z
42 49 8 PRIMARY PARTY IDENTIFIER
Identity of the party to the
trade that is represented by the
Submitting Broker of an EBS.
Acceptable values include MPID,
CRD or OCC Clearing Number.
A-R LJ B
50 57 8 CONTRA PARTY IDENTIFIER
Identity of the contra party to
the trade that is represented by
the Opposing Broker of an EBS.
Acceptable values include MPID,
CRD or OCC Clearing Number.
A-R LJ B
58 80 23 FILLER A LJ B
1 1 1 TRAILER RECORD DATE
One record per submission.
Must be the last record on the file.
Value: High Values or "9"
A X
2 17 16 TOTAL TRANSACTIONS
The total number of transactions.
This total excludes Header and
Trailer Records.
N RJ 9(16) B
18 33 16 TOTAL RECORDS ON FILE
The total number of 80 byte
records. This total includes Header
and Trailer Records, but not the
Datatrak Header Record (i.e., it
does not include the first record
on the file).
N RJ 9(16) Z
34 80 47 FILLER A X(47) B
 
      Field Format
A = Alphanumeric (all caps)
N = Numeric
P = Packed
B = Binary
R = Validation Required
Default
Values

B =
Blanks
Z= Zero
Justify
RJ = Right
Justification
of Data
LJ = Left
Justification
of Data
   

Attachment B

Record Layout for Submission of Trading Information

Transaction Type Security Type
  Equity* Options
Non-Program Trading, Agency A C
Non-Index Arbitrage, Program Trading, Proprietary C  
Index Arbitrage, Program Trading, Proprietary D  
Index Arbitrage, Program Trading, Individual Investor J  
Non-Index Arbitrage, Program Trading, Individual Investor K  
Non-Program Trading, Proprietary P F
Non-Program Trading, Individual Investor I  
Non-Index Arbitrage, Program Trading, Agency Y  
Index Arbitrage, Program Trading, Agency U  
Designated Market Makers S S
Market-Maker   M
Non-Member Market-Maker/Specialist Account   N
Stock Specialist—Assignment   Y
Customer Range Account of a Broker/Dealer   B
Error Trade Q  
Registered Trader Market Maker Transaction Regardless of the Clearing Number   P
Voluntary Professional   W
Joint Back Office   J

* Equity securities include those securities that trade like equities (e.g., ETFs and structured products).


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