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bkshadow

10/01/14 11:18 AM

#405825 RE: t1215s #405819

t215, TRUE, Beasts in the Badlands...

...IMO, it is the nature of the beast in the Badlands; the market makers.

The requirement for them is "to report all trades in a day." Here's the catch in the regulations, "they do not have to report them when the trade actually takes place!

Seriously.

The theory is that the market makers are trying to 'balance the market (I don't buy that) and not "spook or scare" investors in one direction or another. I rather believe that market makers prefer to do this to ACCUMULATE, and not show the volume during the day as it would interfere with there 'collection of shares.

Unfortunately, this is perfectly allowed under FINRA rules on the OTC Markets, so long as they ultimately report "at the end of the day." This then becomes a "Non-Business Day Trade." There, there is another tool they use; reporting Form T compliance for such trades "then reported after hours" (yet not reported) in the pre-open the following trading day.

Per FINRA, "Non-Business Day Trades" are combined with "T+365 Trades" (T+365 Trades are supposed to have serious fees and disclosures assigned; it is really tough to get information from FINRA. Think of it, Trades Reported 365 Days or More AFTER the Trade Date!:



http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p506337.pdf

Reporting Non-business Day Trades and T+365 Trades Pursuant to the amendments, firms are required to report trades executed on non-business days (i.e., weekends and holidays) and trades reported more than 365 days after trade date (T+365) to a FINRA facility. (Today these trades are reported on Form T through FINRA’s Firm Gateway.) Non-business day trades and T+365 trades are assessed regulatory fees under Section 3 of Schedule A to the FINRA By-Laws (Section 3) and are not submitted to clearing by the FINRA facility or disseminated.

In addition, firms must report non-business day trades on an “as/of” basis by 8:15 a.m. the next business day following execution with the unique trade report modifier to denote their execution outside normal market hours; trades not reported by 8:15 a.m. are Marked late. Thus, for example, a trade executed on Saturday must be reported by 8:15 a.m. the following Monday (since the FINRA facilities are not open on Saturday to accept the trade report), and if the trade is not reported by that time, it is marked late. All T+365 trades are reported on an “as/of” basis and are marked late.