Regulatory Trade Reporting

After a trade executes, it must be reported to the appropriate system so regulators and the public can see transaction data. Different security types are reported through different systems, and the exam tests which system covers which security.

TRACE: Trade Reporting and Compliance Engine

  • FINRA-operated system for reporting OTC (over-the-counter) transactions in eligible fixed-income securities
  • Covers: corporate bonds, agency debt, asset-backed securities, and other TRACE-eligible securities
  • All FINRA member firms must report transactions in TRACE-eligible securities
  • Reporting deadline: as soon as practicable, no later than 15 minutes from execution (with a one-minute deadline approved but not yet in effect)
  • FINRA Rule 6700 Series governs TRACE reporting

What TRACE does NOT cover:

  • Municipal bonds (those go through RTRS/EMMA)
  • U.S. Treasury securities
  • Equity securities

Exam Tip: Gotchas

TRACE does NOT cover municipal bonds or Treasury securities. Those go to RTRS/EMMA (munis) or are reported through other Treasury systems. Expect a distractor that puts munis under TRACE.

EMMA: Electronic Municipal Market Access

  • Operated by the MSRB (Municipal Securities Rulemaking Board)
  • Free public access to municipal securities information:
    • Trade data
    • Official statements
    • Continuing disclosures
    • Real-time trade prices
  • Municipal dealers report trades through RTRS, which feeds into EMMA

Think of it this way: EMMA is the public-facing platform where anyone can look up municipal bond information.

Exam Tip: Gotchas

EMMA is free and open to the public. Any investor can look up muni trade prices, official statements, and continuing disclosures without a subscription.

RTRS: Real-Time Transaction Reporting System

  • MSRB-operated system for collecting and disseminating municipal securities transaction data
  • Municipal dealers must report transactions per MSRB Rule G-14
  • Reporting deadline: as soon as practicable, no later than 15 minutes from execution (with a one-minute deadline for electronically executed trades approved but not yet in effect)
  • RTRS feeds data into EMMA for public access

RTRS vs. EMMA: RTRS is the reporting pipeline (where dealers submit data). EMMA is the public website (where investors view data).

Exam Tip: Gotchas

RTRS is the dealer-facing reporting system; EMMA is the public-facing viewer. Both handle munis, but they serve different roles. Do not conflate them.

Trade Reporting Facility (TRF)

  • Used for reporting OTC trades in NMS (National Market System) stocks; these are exchange-listed equities traded off-exchange
  • Governed by FINRA Rule 6000 Series
  • When an exchange-listed stock trades in the OTC market (not on an exchange), the TRF captures that trade

Exam Tip: Gotchas

The TRF reports listed stocks that trade OFF-exchange. On-exchange trades are reported by the exchange itself. Expect a distractor claiming the TRF covers all equity trades.

Reporting Summary

  • TRACE: Corporate bonds, agency debt, ABS (asset-backed securities). Operated by FINRA under Rule 6700 Series.
  • RTRS/EMMA: Municipal securities. Operated by MSRB under Rule G-14.
  • TRF: NMS stocks (OTC trades in listed equities). Operated by FINRA under Rule 6000 Series.

Memory Aid:

  • TRACE = Trading corporate bonds
  • MSRB/EMMA = Municipal bonds
  • TRF = sTocks (equities) traded OTC