ARTICLE
21 September 2021

FINRA Adopts Amendments To Filing Requirements For Quotations Of Non-Exchange-Listed Securities

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Cadwalader, Wickersham & Taft LLP

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The amendment requires that a member file a Form 211 if the member quotes a non-exchange-listed security in a quotation medium.
United States Corporate/Commercial Law

FINRA adopted amendments to FINRA Rule 6432 ("Compliance with the Information Requirements of SEA Rule 15c2-11 ("Initiation or Resumption of Quotations without Specific Information"). The SEC rule "set[s] forth the information review and maintenance requirements for broker-dealers that publish quotations in a quotation medium for securities in the over-the-counter market." The amendment requires that a member file a Form 211 if the member quotes a non-exchange-listed security in a quotation medium.

The amendments update FINRA Rule 6432 so as to conform the requirements of the rule to SEA Rule 15c2-11 as recently amended by the SEC. The SEC amendments permit broker-dealers to use publicly available determinations of information reviews made by a "qualified interdealer quotation system" ("Qualified IDQS"). In addition, the amendments specify the filings that a Qualified IDQS must submit in connection with the trading of securities subject to SEA Rule 15c2-11.

The amendments go into effect on September 28, 2021.

Primary Sources

  1. FINRA Regulatory Notice 21-33: FINRA Adopts Amendments to Rule 6432 Regarding Compliance With the Information Requirements of SEC Rule 15c2-11

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