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FINRA Issues Regulatory Notice Requesting Comment on a Proposal to Publish ATS Volume Data for Corporate Bonds and Agency Debt Securities

On July 9, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 19-22 (the Notice) requesting comment on a proposal to publish alternative trading system (ATS) volume data for corporate bonds and agency debt securities, in a format similar to that currently published for equity securities. The published data would include both the total number of transactions and aggregate dollar volume traded for transactions in a particular corporate bond or agency debt security executed within the ATS and reported to FINRA during the aggregation period. The ATS data would be aggregated on a monthly basis and published with a three-month delay. FINRA would not charge for the aggregated ATS fixed income data, which would be published on FINRA’s website.

Under the proposal, each ATS self-reports to FINRA its aggregate weekly volume information and number of trades, by security, in corporate and agency debt securities that are TRACE-eligible. Self-reporting by ATSs would occur on a security-by-security basis within seven business days after the end of each week. FINRA would then publish the data as described above. FINRA staff would compare the self-reported ATS volume data with the transaction information firms report to TRACE to verify the accuracy of volume and trade counts, and once it is comfortable with relying on trade reporting data to calculate the volume, it would eliminate the self-reporting requirement and derive the published data directly from the transaction information reported to TRACE. The Notice also includes a series of specific questions for which FINRA is seeking feedback. FINRA will consider alternatives based on feedback to the proposal.

In the Notice, FINRA encourages all interested parties to comment on the proposal to publish the ATS data by September 7.

A full copy of the Notice is available here.

©2020 Katten Muchin Rosenman LLPNational Law Review, Volume IX, Number 196


About this Author

Susan Light, Katten Law Firm, Finance Law Attorney, New York

Susan Light focuses her practice on financial services regulatory matters. She counsels broker-dealers, hedge funds, investment banks and financial services clients on enforcement issues involving the Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA), other self-regulatory organizations (SROs) and state and federal regulatory authorities. She has particular experience related to sales practice issues, financial and operational issues, anti-money laundering, crowdfunding, cybersecurity, and cryptocurrencies.

Michael T. Foley, Katten, Lawyer, Finance, FINRA, Chicago
Special Counsel

Michael Foley represents broker-dealers, investment advisers and other financial services industry participants with respect to a broad spectrum of legal and regulatory matters arising under the federal securities laws.

Michael has nearly 20 years of experience in private practice and in-house at both a large, full-service broker-dealer and at an online discount broker-dealer, advising broker-dealers and other financial institutions regarding compliance with the federal securities and commodities laws, and with the regulations of the US Securities and Exchange Commission, the US Commodity Futures Trading Commission and financial industry self-regulatory organizations. 


Leonard Licht is an associate in the Financial Services practice. He advises a broad range of financial market participants, including investment managers to private funds and investors in private funds. Prior to joining Katten, Lenny practiced as a corporate and securities attorney and has also worked in an analytical capacity with a family office.

While in law school, Lenny was a Heyman scholar and member of the Moot Court Honor Society.