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A106.2: As the RIA is part of the same legal entity as the broker-dealer, it is a trader and a trader within the meaning of the rules of the trading report. BD2 should report the trade that presents BD1 and BD2 as the commercial parts on the group`s report, and BD1 is subject to all applicable trade reporting rules (for example. B the 20-minute rule) with respect to trade. BD2 should not declare this as a business with a customer. If the RIA is a separate legal entity that is not a member of FINRA, the RIA is not subject to the commercial reporting rules. (See also OATS FAQ (Compliance) #C3.) A106.6: No For the purposes of commercial transaction regulation, transfers of equity securities under a properly documented pension agreement in good faith are considered financing agreements and not declared transactions. FINRA`s trade reporting rules have some additional exceptions. First, where securities are transferred under an asset acquisition contract (APA), such a transfer of securities is not subject to declaration when (1) the APA is subject to the jurisdiction and approval of an insolvency court; and (2) the APA purchase price is not based on current market prices for securities at or after the APP comes into force and cannot be adjusted. See rules 6282 (f) (1), 6380A (e) (1), 6380B (e) (1) and 6622 (e) (1). Q200.5: Member BD1 is required to report commercial relationships and has entered into an obligation agreement with member BD2, BD2 reporting on behalf of BD1. BD2 does not declare trading within 10 seconds of execution, in accordance with the rules governing commercial relations. Can BD1 be debited from the declaration of trade balance notes? A Qualified Special Representation Agreement (QSR) allows brokers to conduct transactions without using the Nasdaq ACT system. Using a QSR allows a broker to process trades more efficiently, more easily and at a lower cost.

A QSR also allows brokers to trade after or before regular trading hours. If the parties declare that the exchanges are « blocked » pursuant to an abandonment agreement (see section 200), the 20-minute rule does not apply. The Universal Trade Capture System uses the relationship between countervailing members and their export brokerage identifiers as part of its commercial validation process. A200.1: Yes. A member may authorize another member to notify and block transactions on his behalf to a TRF, ADF or ORF, provided that both parties have entered into an agreement (a « give-up » agreement) as defined by the FINRA (FINRA Transparency Services Uniform Reporting Agreement) and have submitted this agreement to the FINA FACILITY (or entities) for which the relationship « give-up » applies. See rules 6282 (h), 6380A (h), 6380B (g) and 6622 (h); NASD Members` Warning: Notice to all participants in the TRF, ADF and other NASD facilities via the AGU and QSR relationships (25 January 2007).