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ATTENTION broker-dealers that post order routing reports pursuant to SEC Rule 606(a): You have a new reporting obligation. Starting with the Rule 606(a) report for the second quarter this year — which, of course, is due on or before July 31 — you must also file your report with FINRA via Firm Gateway in addition to posting it to your website. See new FINRA Rule 6151.

I have no doubt that, as FINRA states in Regulatory Notice 24-05, this new requirement will make these reports more accessible for who review and analyze the data. I also have no doubt that this new filing will also make it easier for FINRA and the SEC to detect late postings. To paraphrase Jim Nantz since the Masters golf tournament just concluded, this will be a carbon copy unlike any other.

This is a good opportunity for broker-dealers to review their process and procedures to ensure that they afford enough time to generate, review (and if necessary, revise) and post these reports to FINRA within the rule’s requirement. FINRA will be watching.

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Because broker-dealers, registered investment advisers and their associates want to spend their time serving their clients, not the SEC, FINRA or state regulators.