DD Support Board and Research Team

[BigBake1]

I have got you an answer:

They are Regulatory fees assessed by the specific Broker for each transaction, unlike regular commission costs, this Regulatory fee is normally absorbed by the broker, but has instead been passed to the customer for their transaction. So in this case whomever is using a certain broker for a Block Position is in fact being assessed in shares per transaction for FINRA fees. It is called a Section 31 fee, and yes even the SEC applies such a fee per transaction.

The reason they started becoming numerous was due to the ODD LOT transaction reporting requirements, although the transaction is above the 100 share threshold currently it wasnt a requirement until December to report them.

It took 20 minutes to get an answer and pointed in the right direction, it has in fact been updated in the latest FINRA Trade Reporting Requirements:

Section 604: Odd Lot Transactions

Q604.1:What is an odd lot for purposes of the trade reporting rules?

A604.1: For purposes of the trade reporting rules, an odd lot is less than a “normal unit of trading,” which is generally defined as “100 shares of a security unless, with respect to a particular security, FINRA determines that a normal unit of trading shall constitute other than 100 shares.” See, e.g., Rules 6320A and 6320B.

Q604.2: How should odd lot transactions be reported to FINRA for regulatory transaction fee purposes?

A604.2: When reporting odd lot transactions to FINRA for regulatory transaction fee purposes, firms must mark the trade report for media dissemination (i.e., “for publication” or as “tape eligible”), and report to FINRA within 10 seconds of trade execution. See, e.g., FAQ 102.1.

Q604.3: Are odd lot transactions disseminated?

A604.3: Effective December 9, 2013, reports of odd lot transactions that are marked “for publication” or as “tape eligible” are publicly disseminated by FINRA and the securities information processors, as applicable; however, odd lot transactions do not update the high, low and last sale price for the security. For certain high-priced OTC Equity Securities, FINRA will continue to change the "unit of trade" from 100 shares to one share; transactions in such securities below 100 shares will be disseminated as round lot transactions and will update the high, low and last sale price See Trade Reporting Notice 3/18/08 (Revised Policy for Disseminating Reports of Fewer Than 100 Shares).