FINRA Rule 6830

Where errors in previously submitted Industry Member Data have been identified, whether by the Plan Processor's own validation checks or discovered through the Industry Member's own review, the Industry Member must submit corrected data to the Central Repository by 8:00 a.m. Eastern Time on T+3. This three-business-day correction window gives firms meaningful time to investigate and fix an identified discrepancy, but it is a hard deadline rather than an aspirational target, and firms should treat it with the same seriousness as the original reporting deadline itself.

Symbology and Identification Requirements

Rule 6830 addresses a practical complication that arises whenever a single security can trade across multiple venues using potentially different symbol conventions. For each exchange-listed Eligible Security, an Industry Member must report Industry Member Data using the symbology format of the exchange that actually lists that security, rather than a FINRA-specific or universal symbology standard. For Eligible Securities that are not exchange-listed, Industry Members instead use whatever symbology format the CAT NMS Plan's Operating Committee has approved, giving the Operating Committee centralized authority to standardize identification for the broader universe of non-listed OTC Equity Securities that fall within CAT's scope.

Rule 6830 also incorporates a unique trade identifier requirement tied to a member's use of FINRA's equity trade reporting facilities. Where an Industry Member reports the execution or cancellation of an order to the Central Repository pursuant to specific provisions of Rule 6830(a)(1), that member must also report the trade identifier it used when reporting the same trade to the relevant FINRA facility, whether that is a Trade Reporting Facility, the OTC Reporting Facility, or the Alternative Display Facility. This requirement phased in on a schedule tied to firm size and prior OATS reporting status: the trade identifier reporting obligation began June 22, 2020 for Large Industry Members and Small Industry Members that had previously been OATS reporters, and began December 13, 2021 for Small Industry Members that had not previously reported to OATS, with the corresponding uniqueness requirement, ensuring the identifier is not reused across different trades, phased in on largely parallel dates.

The Options Market Maker Carve-Out

Rule 6830 contains a specific accommodation for Options Market Makers that differs meaningfully from the reporting framework applicable to other Industry Members. An Industry Member that is an Options Market Maker is not required to report to the Central Repository the routing, modification, or cancellation of its own quotes in Listed Options. Instead, that Options Market Maker reports to the relevant Exchange the time its quote in a Listed Option is sent to that Exchange, along with any subsequent quote modification or cancellation time where the Options Market Maker itself originated that modification or cancellation, and the Exchange bears responsibility for incorporating that information into CAT on the market maker's behalf.

This carve-out exists because options market maker quoting activity operates at extremely high volume and velocity, and requiring each individual market maker to separately report every quote event directly to the Central Repository, duplicating information the relevant exchange already captures as part of its own quote dissemination infrastructure, would impose considerable redundant reporting burden without generating meaningfully more accurate or complete data than routing that same information through the exchange itself. Firms relying on this carve-out should understand it applies specifically to quoting activity; an Options Market Maker's other CAT reporting obligations, including those tied to orders it receives from others rather than its own proprietary quoting, are not affected by this exception.

The 2025 Bona Fide Market Making Exception Reporting Requirement

Rule 6830 received a significant, recent amendment addressing short sale reporting specifically. In 2023, the SEC amended the CAT NMS Plan itself to add a new requirement to Section 6.4(d)(ii), requiring each Participant, through its own Compliance Rule, to require Industry Members to record and report whether an order to sell an equity security is a short sale a market maker is effecting in connection with bona fide market making activities under the exception in Rule 203(b)(2)(iii) of SEC Regulation SHO, commonly referred to as the BFMM Locate Exception. This Regulation SHO exception permits a market maker engaged in genuine, bona fide market making activity to sell short without first borrowing or arranging to borrow the security, an accommodation not available to ordinary short sellers, who must satisfy Regulation SHO's standard locate requirement before executing a short sale.

FINRA implemented this CAT NMS Plan-level requirement into its own Compliance Rule through SR-FINRA-2025-016, filed with the SEC on December 12, 2025, adding new subparagraph (G) to Rule 6830(a)(2). This provision requires an Industry Member to record and report, for the original receipt or origination of an order to sell an equity security, whether that order is a short sale a market maker is effecting under the BFMM Locate Exception. FINRA filed this change for immediate effectiveness and specifically requested that the SEC waive the standard 30-day operative delay, allowing the requirement to take effect promptly rather than waiting out the ordinary implementation runway, reflecting FINRA's position that the change simply implements an already-adopted CAT NMS Plan requirement rather than introducing any novel regulatory question.

This new reporting field gives FINRA and other regulators direct visibility into which short sale orders are relying on the bona fide market making exception, a category of trading activity that has historically drawn regulatory attention given the potential for the exception to be claimed in circumstances that do not genuinely reflect bona fide market making. Firms whose trading desks include market making activity in equity securities should confirm their CAT reporting systems correctly capture and transmit this new data element for every qualifying order, since it represents a genuinely new field that did not exist in Rule 6830's reporting content before this amendment.

Adjacent Developments in Trade Reporting Hours

Firms should be aware of a related, though technically separate, development affecting the broader trade reporting infrastructure Rule 6830 interacts with. FINRA has amended Rules 6380A and 6380B, governing the FINRA/Nasdaq and FINRA/NYSE Trade Reporting Facilities, to extend TRF operating hours from an 8:00 a.m. opening to a 4:00 a.m. opening each business day, effective March 30, 2026. This change enables real-time public dissemination of OTC transactions in NMS stocks executed between 4:00 a.m. and 8:00 a.m., a window that previously required next-day "as/of" reporting treatment. While this amendment does not itself modify Rule 6830's text, firms should recognize that CAT reporting obligations for order events connected to trades reported through these extended-hours facilities will need to account for this broader operating window as the change takes effect.

The Full Scope of Reportable Order Events

Rule 6830's data requirements span the complete lifecycle of an order rather than capturing only its final outcome. For an order that is executed, in whole or in part, the required data includes the SRO-Assigned Market Participant Identifier of the clearing broker where applicable, alongside a range of other fields identifying the specific circumstances of that execution. For the original receipt or origination of an order, Industry Members must report the Firm Designated ID associated with the relevant Customer, along with Customer Account Information and Customer Identifying Information as those terms are defined in Rule 6810 and further detailed in Rule 6840.

This lifecycle approach means a single order can generate multiple distinct Reportable Events over its lifetime, an original receipt event, one or more routing events if the order moves between desks or out to another venue, modification events if material terms change, and finally an execution or cancellation event marking its conclusion. Each of these distinct events carries its own specific data reporting requirements under Rule 6830, and the Central Repository relies on the CAT-Order-ID linkage discussed in the Rule 6810 entry to stitch these individually reported events back together into a coherent, chronological picture of the order's complete history spanning every firm and venue it touched along the way.

Why the Received Versus Recorded Distinction Matters

The distinction between Recorded Industry Member Data, reported contemporaneously with the triggering event, and Received Industry Member Data, reported by 8:00 a.m. the following Trading Day, reflects a deliberate design choice accommodating different categories of information a firm's own systems handle differently in practice. Recorded data generally corresponds to events a firm's own systems generate in real time as part of order handling and execution, information the firm's technology infrastructure is naturally positioned to capture and transmit essentially as it happens. Received data, by contrast, often corresponds to information a firm obtains from an external source, such as customer account details supplied by the customer or an introducing broker, information that may not arrive in a form ready for immediate, real-time CAT submission even though the underlying event itself may have occurred earlier that day.

This distinction matters practically for how firms design their CAT reporting workflows. A firm should not assume that all of its Rule 6830 reporting obligations operate on the same contemporaneous, real-time cadence; some data genuinely requires the overnight processing window Received Industry Member Data reporting provides, and building unnecessary real-time reporting infrastructure for data that legitimately falls into the Received category represents wasted engineering effort better directed elsewhere in a firm's CAT compliance program.

Relevance Across FINRA's Exam Programs

The SIE, Series 63, and Series 65 do not test Rule 6830's specific reporting content requirements, since these exams do not reach into the granular technical infrastructure underlying CAT reporting. A Series 7 candidate gains limited direct value here, though understanding that essentially every order event in an NMS stock or OTC Equity Security generates a corresponding CAT reporting obligation reinforces broader awareness of how comprehensively FINRA's market surveillance infrastructure now covers order activity.

A Series 24 candidate supervising equity trading operations needs genuine command of Rule 6830's core deadlines, the 8:00 a.m. Eastern Time next-Trading-Day requirement for Received Industry Member Data and the T+3 correction deadline, since a principal's supervisory procedures should specifically address how the firm monitors compliance with both. A Series 24 candidate at a firm with market making operations should also understand the new BFMM Locate Exception reporting requirement specifically, given its direct connection to short sale compliance oversight the principal is likely already responsible for under Regulation SHO more broadly. A Series 57 candidate handling options market making activity needs precise understanding of the Options Market Maker carve-out, recognizing that quote-related CAT reporting flows through the Exchange rather than requiring direct submission by the market maker itself, while other order-related reporting obligations remain unaffected by that carve-out.

Practical Guidance for Firms

Firms should treat the 2025 BFMM Locate Exception reporting requirement as a genuine system change requiring dedicated testing and validation, not a minor field addition that existing infrastructure will automatically capture correctly. Given that FINRA requested and received an accelerated, immediately effective implementation rather than the standard 30-day runway, firms with market making operations should prioritize confirming their order management and CAT reporting systems correctly populate this new field for every qualifying short sale order, rather than assuming legacy reporting logic built before this requirement existed will handle it correctly by default.

Firms should also build the symbology and trade identifier requirements into their CAT reporting quality assurance program as a distinct category of potential error, separate from more commonly discussed timing and content accuracy issues. A firm reporting an exchange-listed security using an incorrect symbology format, or failing to correctly link its CAT trade identifier to the corresponding identifier used in its FINRA facility trade report, creates a data linkage problem that may not surface as an obvious error but nonetheless undermines the Central Repository's ability to correctly reconstruct the full picture of a given trade across both reporting streams.

Given how frequently Rule 6830 continues to be amended in response to CAT NMS Plan-level changes, firms should build ongoing monitoring of both FINRA rule filings and CAT NMS Plan Operating Committee actions directly into their CAT compliance program, rather than treating Rule 6830 as a largely settled, static reporting requirement. The BFMM Locate Exception amendment illustrates a recurring pattern: a substantive change originates at the CAT NMS Plan level, sometimes years before FINRA's own Compliance Rule catches up to reflect it, meaning firms monitoring only FINRA's rule text directly risk being caught off guard when FINRA does eventually implement a Plan-level requirement that has, in principle, already been determined and simply awaits FINRA's own conforming rule change. A firm that assigns dedicated ownership for tracking CAT NMS Plan Operating Committee developments, distinct from ordinary FINRA rule-filing monitoring, is better positioned to anticipate these conforming amendments before they arrive with an accelerated, immediately effective implementation timeline of the kind FINRA used for this particular change.

Firms should also treat the Options Market Maker carve-out and the broader options quoting infrastructure it relies upon as a distinct area of compliance verification, particularly for firms that maintain both an options market making desk and other order-handling business lines subject to the ordinary Rule 6830 reporting framework. A firm should periodically confirm that its exchange-facing quote reporting genuinely satisfies the substance of what the carve-out contemplates, since relying on the exception incorrectly, for example applying it to order-related activity that falls outside its intended quoting-only scope, could leave gaps in the firm's actual CAT reporting coverage that neither the firm's own systems nor the relevant exchange's quote-reporting infrastructure are positioned to catch on the firm's behalf.