The Financial Industry Regulatory Authority has issued a notice clarifying the “as soon as practicable” requirement under FINRA reporting rules for transactions effected over-the-counter (OTC). As background, FINRA rules provide that OTC trades in national market system (NMS) securities that are executed during the hours that a FINRA trade reporting facility is open must be reported for dissemination purposes as soon as practicable, but no later than 10 seconds, following trade execution.

As set forth in the notice, FINRA interprets the “as soon as practicable” requirement to prohibit a firm from releasing information relating to OTC transactions in NMS securities to other market participants any sooner than the firm releases such information to a FINRA trade reporting facility for dissemination (or “tape”) purposes.

FINRA’s notice is available here.