Achieving Market Making Status

Quick Answer

Market maker status depends on the definition: the statute says regular or continuous holding out, the Alternative Display Facility says regular and continuous. Pulling quotes can end a registration, issuer payments for quoting are barred outside three carve-outs, and market maker net capital runs $2,500 per security, or

Quick Answer: Market maker status depends on the definition: the statute says regular or continuous holding out, the Alternative Display Facility says regular and continuous. Pulling quotes can end a registration, issuer payments for quoting are barred outside three carve-outs, and market maker net capital runs $2,500 per security, or $1,000 at $5 or less.

,000 at $5 or less.

Who counts as a market maker, how status is gained and lost, and what it costs in capital.


Which One-Liners Win Points?

  • The statute's holding-out limb reaches a dealer willing to buy and sell a security for its own account on a regular or continuous basis, by quotations "or otherwise." A dealer acting as block positioner needs no quote.
  • A Registered Reporting Alternative Display Facility (ADF) Market Maker holds out on a regular and continuous basis, only in the designated securities it is registered in.
  • Over-the-counter (OTC) Market Maker status runs security by security, where the member displays market making interest through an inter-dealer quotation system.
  • Market participant identifier (MPID): every ADF Participant obtains one before trade input, even if a third party reports for it. More than one for OTC equity quoting or OTC Reporting Facility reports needs FINRA Market Operations' approval on a written request.
  • Floor broker cross, manual transactions only: offer above your own bid by the minimum variation and announce both to the Crowd, with a Trading Official present, first.
  • Payments for market making: no member or associated person may accept payment or other consideration, directly or indirectly, from an issuer, its affiliate or its promoter for publishing a quotation, acting as market maker, or applying to do either.
  • Payment carve-outs: bona fide services; reimbursement of registration payments imposed by the SEC or state regulatory authorities and of listing payments imposed by a self-regulatory organization; and payments expressly provided for under national securities exchange rules effective after being filed with, or filed with and approved by, the SEC.

Which Numbers Matter Most?

ItemValue
Market maker net capital$2,500 per security, or $1,000 at $5 or less, on a 30-day average; capped at $1,000,000 unless the general requirement demands more
Qualified block positioner$1,000,000 net capital; blocks worth $200,000 or more
ADF voluntary terminationQuotes withdrawn for 5 minutes, or not re-entered within 30 minutes after a halt ends
Re-registering after terminationBarred 20 business days, absent an excused withdrawal

Which Gotchas Trip Students Up?

  • Net capital is the greater of the ratio requirement or the highest activity minimum, not their sum, and the market maker computation never drops below it.
  • Excused withdrawal status "may be granted," never automatically. An ADF Trading Center asks first, unless it cannot submit automated quotations or respond immediately and automatically to orders; then it withdraws at once and promptly contacts ADF Operations.
  • Never a ground: pending news, a sudden influx of orders or price changes, or withdrawing to trade with competitors.
  • A market maker whose clearing-arrangement failure terminates its registration in Nasdaq securities skips the 20-business-day bar. It may register at any time after a clearing arrangement has been reestablished.
  • The qualified categories serve Regulation U, the Federal Reserve's credit regulation, and the block positioner sells as rapidly as possible commensurate with the circumstances; no day count applies.

One-Breath Recap

The statute's market maker is a specialist permitted to act as a dealer, a dealer acting as block positioner, or a dealer holding out as willing to buy and sell a security for its own account on a regular or continuous basis. An Alternative Display Facility market maker quotes on a regular and continuous basis, and withdrawing quotes for five minutes, or missing the 30-minute re-entry after a halt, ends its registration in that security and bars re-registering for 20 business days, absent an excused withdrawal. A qualified block positioner needs $1,000,000 in net capital and blocks worth $200,000 or more. A market maker computes net capital at $2,500 per security, or $1,000 at $5 or less. Issuer payments for quoting are barred outside three carve-outs.


Need more than the recap? Read the full Achieving Market Making Status unit.