Quick Answer
FINRA publishes aggregate weekly volume for each alternative trading system with the trade reporting obligation, no earlier than two weeks for Tier 1 national market system stocks and four weeks for others, and four weeks for over-the-counter equity securities. The published information includes the number of shares and the number of trades.
The publication duty here sits on FINRA, not on the member. What the member owes is the trade report that feeds it, and that duty is covered in the unit on reporting trades to the designated reporting facility.
What Does FINRA Publish About Each Alternative Trading System?
For each alternative trading system (ATS) with the trade reporting obligation, FINRA publishes on its public website the aggregate weekly ATS Trading Information, on timeframes that differ by security type.
| Securities | Earliest publication |
|---|---|
| National market system (NMS) stocks in Tier 1 of the Limit Up-Limit Down Plan | No earlier than two weeks following the end of the ATS Trading Information week |
| NMS stocks that are subject to FINRA trade reporting requirements and are not in Tier 1 of that plan | No earlier than four weeks following the end of the ATS Trading Information week |
| Over-the-counter equity securities | No earlier than four weeks following the end of the ATS Trading Information week |
FINRA also publishes monthly aggregate ATS block trading statistics for each alternative trading system with the NMS stock trade reporting obligation. Their elements are to be determined from time to time by FINRA in its discretion, as stated in a Regulatory Notice or other equivalent publication.
For each such system, those statistics are aggregated across all NMS stocks, cover a minimum time period of one month of trading, and are published no earlier than one month following the end of the month for which trading was aggregated.
For NMS stocks, an ATS has the same meaning as the term alternative trading system as defined in Regulation ATS. That definition is covered in the unit on display, execution and trading systems.
Exam Tip: Gotchas
- The two-week window is the exception, not the rule. Only Tier 1 NMS stocks publish that early; every other NMS stock and every over-the-counter equity security waits at least four weeks.
- Block statistics exist for NMS stocks only. The over-the-counter equity publication is the weekly figure, and no monthly block trading statistic is set for it.
What Counts as ATS Trading Information?
For the NMS stock rule, ATS Trading Information includes two items.
- The number of shares of an NMS stock executed on an alternative trading system with the trade reporting obligation and reported to FINRA.
- The number of trades in an NMS stock executed on such a system and reported to FINRA.
The over-the-counter equity rule uses the same two items, measured on an over-the-counter equity security executed on an alternative trading system with the trade reporting obligation and reported to FINRA.
Exam Tip: Gotchas
- The definition is introduced with "includes". The rule names two items rather than declaring that the term is limited to them, so read a question about the contents as asking what the rule names.
- Both items are reported figures. They count what was executed on the system and reported to FINRA.
How Is a Member's Own Trading Information Published?
FINRA runs a parallel publication for a member's own trading outside an alternative trading system. The trade reporting duty that feeds it belongs to the unit on reporting trades to the designated reporting facility.
Trading Information is aggregated for all Market Participant Identifiers (MPIDs) used by a single member, excluding, if applicable, any MPIDs the member uses for reporting trades executed in its alternative trading system.
A member's Trading Information includes the number of shares and the number of trades executed by the member with the trade reporting obligation and reported to FINRA. Each publication rule then adds that Trading Information shall not include any ATS Trading Information.
Why Are the Two Figures Published Separately?
A member that operates an alternative trading system reports that venue's trades under a separate market participant identifier. Both publication rules then strip those identifiers out of the member's own published Trading Information, and both state expressly that a member's Trading Information shall not include any ATS Trading Information.
The result is two separate published measures. The alternative trading system's volume is published against the system, and the member's own volume is published against the member with the system's activity removed.
Exam Tip: Gotchas
- The member figure is not a combined member-and-system figure. It excludes the system's trades, which belong to the separate system publication.
- The exclusion is written more than once. It appears once through the identifier carve-out and again as a flat statement that the member figure shall not include ATS Trading Information.
What Should You Check on Exam Day?
- Put the publication duty on FINRA and the reporting duty on the member; only the report is something a firm does.
- Match the security to its lag: two weeks for Tier 1 NMS stocks, four weeks for other NMS stocks and for over-the-counter equity securities.
- Expect monthly block trading statistics for NMS stocks, and do not expect an over-the-counter equity block figure.
- Read ATS Trading Information as the number of shares and the number of trades executed on the system and reported to FINRA.
- Keep the two published measures distinct: the member figure excludes its alternative trading system's volume.