FINRA and ISG Postpone Effective Dates for Enhanced Electronic Blue Sheet Submission


FINRA issued Regulatory Notice 11-56 (RN 11-56) on December 13, 2011, which announced enhancements to EBS. These enhancements, which were a joint effort of FINRA and the ISG interested members, were designed “to improve the regulatory agencies’ ability to analyze broker-dealers’ trading activities.” FINRA and the ISG interested members have now extended the compliance dates for the Blue Sheet reporting requirements to November 30, 2012 and May 1, 2013, so that broker-dealers have additional time to develop, test and implement the enhancements.

By November 30, 2012, broker-dealers must be in Blue Sheet reporting compliance with the seven new fields described in RN 11-56, which may apply to all National Market System securities and for all transactions effected (directly or indirectly) by or through (a) any proprietary account of a U.S. registered broker-dealer or (b) any account used by a customer that trades through a “sponsored access” arrangement.

By May 1, 2013, broker-dealers must be in Blue Sheet reporting compliance for the “Order Execution Time, Entering Firm Identifier and Executing Firm Identifier” fields in all securities and all types of transactions effected (directly or indirectly) by or through all types of accounts that are Blue Sheet reportable.

Click here to read the full text of Regulatory Notice 12-36


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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