Trade reporting is the regulatory process by which broker-dealers submit the details of each completed securities transaction — price, size, execution time, capacity, and any special conditions — to a FINRA-operated facility within a defined window after the trade. Those reports feed public market data, give regulators the raw material for surveillance, and establish an audit record for every fill. The exact facility, deadline, and data fields depend on the asset class: equities, corporate bonds, Treasuries, and securitized products each follow their own rules.
Which Firm Has to File the Report
FINRA assigns the obligation to the “executing party” — the firm that takes the order, does not route it elsewhere, and actually fills it. When two FINRA member firms trade with each other and both could qualify, the sell-side firm reports unless the parties agree otherwise and the sell-side firm documents that agreement at the time of the trade.1FINRA. FINRA Rule 6380A – Transaction Reporting When a member firm trades with a non-member or a customer, the member always reports.2FINRA. FINRA Rule 6282 – Transactions Reported by Members to the ADF
The hierarchy prevents duplicate filings while making sure every trade gets recorded once. FINRA’s Rule 6000 Series governs quotation and transaction reporting for equity securities; the Rule 6700 Series covers fixed-income reporting through TRACE.3FINRA. FINRA Rule 6000 – Quotation, Order, and Transaction Reporting Facilities
What Goes in a Trade Report
Every report carries a core set of fields that identify what traded, at what price, in what quantity, and when. The security is identified by a standard identifier such as a CUSIP number or ticker symbol. The report states the execution price, the number of shares or units exchanged, and the exact time of execution in hours, minutes, and seconds, expressed in Eastern Time military format.4FINRA. FINRA Rule 6380B – Transaction Reporting The firm also discloses its capacity — whether it acted as agent for a customer or as principal trading for its own account.
Beyond those basics, reports carry modifiers that flag non-standard conditions. Settlement modifiers indicate whether the trade settles regular-way, cash (same-day), or on a seller’s option. Late-report indicators flag trades reported after the allowed window and distinguish trades executed during normal hours from those executed outside them. Pricing modifiers identify trades using a weighted average price, prior reference price, or other formula that doesn’t reflect the current market. Trade-through exemption codes explain why a trade executed outside the best available quote, such as intermarket sweep orders or qualified contingent trades.
Reports with missing required fields are typically rejected by the reporting system, forcing the firm to resubmit before the filing counts as timely. Missing or incorrect modifiers get a report flagged during surveillance review.5FINRA. Trade Report Modifiers and Applicability of Limit Up/Limit Down (LULD) Price Bands
Where the Report Goes
Routing to the correct facility is mandatory, and the right destination depends on the type of security.
Equities
Over-the-counter trades in NMS stocks — exchange-listed equities traded away from an exchange — are reported to one of FINRA’s Trade Reporting Facilities. Each TRF is affiliated with a national securities exchange but operates under FINRA’s authority.6FINRA. Trade Reporting Facility (TRF) The Alternative Display Facility is a narrower venue that lets registered market makers and electronic communications networks display quotations, compare trades, and report transactions in NMS stocks; the ADF is display-only, with no automated order routing or execution capability.7Federal Register. Notice of Filing and Immediate Effectiveness of a Proposed Rule Change
Trades in OTC equity securities — non-NMS stocks such as OTC Markets securities, ADRs, foreign securities, and certain direct participation programs — go to the OTC Reporting Facility. The ORF also handles transactions in restricted equity securities under SEC Rule 144A.8FINRA. Trade Reporting Frequently Asked Questions
Fixed Income and Securitized Products
FINRA’s Trade Reporting and Compliance Engine, TRACE, handles mandatory reporting of OTC transactions in eligible fixed-income securities. It captures corporate bonds, agency debt, asset-backed securities, mortgage-backed securities, and U.S. Treasury securities.9FINRA. What Is TRACE and How Can It Help Me? Treasury transactions are disseminated to the public on a next-day basis rather than in real time. TRACE also covers securitized products such as collateralized mortgage obligations, collateralized loan obligations, and private-label commercial mortgage-backed securities. Every FINRA member broker-dealer must report transactions in any TRACE-eligible security under FINRA Rule 6700.10FINRA. Trade Reporting and Compliance Engine (TRACE)
How Fast the Report Has to Be Filed
Deadlines vary sharply by asset class. Equities face the tightest window; some securitized products have until the end of the trading day.
Equities: Ten Seconds
All OTC equity transactions, whether NMS stocks reported through a TRF or OTC equity securities reported through the ORF, must be transmitted as soon as practicable and no later than ten seconds after execution during normal market hours. Anything filed after that window must be flagged as late.4FINRA. FINRA Rule 6380B – Transaction Reporting11FINRA. FINRA Rule 6622 – Transaction Reporting
TRACE: Minutes to End of Day
Under FINRA Rule 6730, as of 2026:
- Corporate bonds and agency debt: within 15 minutes of execution.
- Asset-backed securities and agency pass-through MBS traded TBA for good delivery: within 15 minutes.
- U.S. Treasury securities: within 60 minutes of execution, with a T+1 exception for trades hedging primary market transactions.
- CMOs and REMICs: within one hour for most transactions; trades executed before the security is issued may be reported as late as the first settlement date.
- CDOs, CLOs, CBOs, and private-label CMBS: same day during TRACE business hours.
FINRA considered shortening the 15-minute window to one minute for fully electronic trades but reversed course in 2025 and kept the 15-minute standard in place.12U.S. Securities and Exchange Commission. Order Approving a Proposed Rule Change to Amend FINRA Rule 673013FINRA. TRACE Reporting and Dissemination
How Trade Reporting Differs From the Consolidated Audit Trail
Trade reporting captures completed transactions. A separate system, the Consolidated Audit Trail, tracks the full lifecycle of every order in NMS securities — placement, modifications, cancellations, routings, and the final execution or cancellation. Created under SEC Rule 613, the CAT runs alongside the FINRA transaction facilities rather than replacing them.14U.S. Securities and Exchange Commission. Rule 613 (Consolidated Audit Trail)
Both national securities exchanges and FINRA member broker-dealers must report to the CAT. The deadline is 8:00 a.m. Eastern Time on the trading day following the day the data was recorded, and anything submitted after that is marked late.15CAT NMS Plan. FAQs Errors must be corrected within three trading days, a T+3 deadline FINRA specifically monitors during examinations.16FINRA. Consolidated Audit Trail
The CAT also imposes clock synchronization standards. Exchanges must synchronize their business clocks to within 100 microseconds of National Institute of Standards and Technology time. Broker-dealers must synchronize to within 50 milliseconds of NIST time for electronic events and within one second for manual order events and allocation reports. Firms certify compliance each year by March 15.17U.S. Securities and Exchange Commission. Consolidated Audit Trail Clock Synchronization Assessment18CAT NMS Plan. Clock Synchronization
What Happens When Firms Report Incorrectly
FINRA does not publish a fixed fine schedule for trade reporting violations. Its Sanction Guidelines give adjudicators recommended ranges and a list of factors — scope of the failure, whether it was intentional, the firm’s disciplinary history — to calibrate penalties case by case. The guidelines state that sanctions must be “meaningful and significant enough to prevent and discourage future misconduct” and cannot be treated as a cost of doing business.
Repeat offenders face escalating consequences. Adjudicators are required to impose progressively heavier sanctions on firms with a pattern of violations, up to barring individual employees or expelling the firm from FINRA membership. The dollar amounts can be substantial: in a 2024 enforcement action, a major broker-dealer paid a $2 million fine for systematic TRACE reporting failures. That kind of outcome is more realistic for large-scale or prolonged violations than for isolated late reports, but it signals how seriously regulators treat reporting accuracy.