OATS SM Subscriber Initiation And Registration Form
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1 (Use for Phase 3 registration) OATS SM Subscriber Initiation And Registration Form ***Please read all instructions carefully prior to filling out the form*** Please complete and return this Order Audit Trail System SM (OATS SM ) Subscriber Initiation and Registration Form to NASD. Registration for OATS using this Form is mandatory for all NASD member firms receiving and/or handling orders for NASDAQ securities. If your firm has not registered, Sections 1-4 of this Form must be completed and submitted, and Section 5 activities must be successfully completed. If your firm has already registered, refer to the checklist in Section 5 and ensure your firm has performed all required registration activities. Some previously registered firms may be required to submit an amended form. NASD member firms that fail to complete and return this Form or fail to perform all required registration activities will not be able to report OATS data to NASD; failure to report order information by the specified OATS implementation date is in violation of NASD Rules 6955 and 6956 which may be considered to be in violation of NASD Rule For additional information about Registration and OATS reporting refer to NASD Rules 6950 through 6957 and Notice to Members 98-33, 98-73, and Information about OATS is also available via the NASD Web Site at If you have any questions regarding OATS or this Form, please contact NASD via phone at NASD or via at supportservices@nasd.com. This Form may be mailed or faxed to: NASD Business and Technology Support Services ATTN: OATS Registration\Gateway Call Center 9509 Key West Avenue Rockville, MD Fax: ***Please read all instructions carefully prior to filling out the form***
2 Section 1: Organization Data Please provide your organization name and, if you are an NASD member firm, provide your Broker Dealer Number and Market Participant Identifier (MP ID). [NOTE: The MP ID was formerly called the Market Maker Identifier (MMID)]. All member firms that are subject to OATS or ACT reporting must have an MP ID. If you do not have an MPID, please contact Nasdaq Subscriber Services at If a business change causes a member firm to meet the reporting criteria for a different Phase than originally reported, an amended version of this registration form must be returned immediately to ensure compliance with OATS Rules. Organization Name: Broker Dealer Number: Market Participant ID: New Registration Amended Registration Section 2: OATS Reporting Phase NASD Member Firm Non-member third party transmitting to OATS Non-member software provider If you are an NASD member firm, indicate the Phase in which your organization is required to begin reporting OATS data, based on Rule If you are not a member of NASD, but you will act as a third party to transmit order information to OATS, indicate the Phase when you will begin transmitting data to OATS on behalf of member firms. If you are a software provider that will not be transmitting to OATS on behalf of member firms, but you are registering to use the OATS testing environment, indicate Not Applicable. Phase 1 and Phase 2: Phase 3: Electronic orders of market makers and ECNs. (Phase 1) Electronic orders of all member firms (Phase 2). Electronic orders are orders received or captured via an electronic order routing or execution system. Electronic orders can be routed or executed manually (e.g., via telephone). Manual, or non-electronic, orders are captured by a member firm in some way other than in an electronic order routing or execution system, such as on a paper ticket. Select one: Phase 1 or 2 Phase 3 Not Applicable Manual orders are not required to be reported during Phases 1 and 2; thus, during these two phases, orders that are captured in some way other than in an electronic order routing or execution system need not be reported. However, during these two Phases, an order that is initially captured manually and later entered into an electronic order routing or trading system is reported as an electronic order, with the order receipt time as the time of receipt at a market maker s trading desk (Phase 1), or the time of entry into the electronic system (Phase 2). OATS Subscriber Initiation and Registration Form Page 2 of 6
3 If you selected Phase 1 or 2, please provide the date the firm first intends to test or tested an electronic routing or execution system and a brief explanation of the steps taken to ensure compliance with OATS reporting requirements. If you selected Phase 1 or 2, please provide the date the firm first started receiving orders via an electronic routing or execution system. Section 3: Reporting Mechanism Check All That Apply: My organization will report directly to OATS via File Transfer Protocol (FTP). (Refer to Section 5 for circuit ordering procedures.) My organization will report directly to OATS via CONNECT:Direct. (Refer to Section 5 for circuit ordering procedures.) My organization will report directly to OATS via . (Refer to Section 4.4 in the OATS Subscriber Manual). My organization will send order data directly to OATS via the OATS Web interface (NOTE: This option is recommended for firms that will report fewer than 100 order reports per day). My organization will send order data directly to OATS via Internet File Transfer (IFT). a) Check your Client Type Windows Unix b) Number of Clients to be used: c) List your current OATS transmission method: Other organizations will report order data to OATS on my organization s behalf. (If this option is selected, please answer questions a, b and c below. a) Because some organizations may transmit data on your behalf before your reporting date, check the earliest phase when your order data will be reported to OATS: Phase 1 or 2 Phase 3 OATS Subscriber Initiation and Registration Form Page 3 of 6
4 b) List all of the organizations that will be submitting order data on your behalf: c) Does your firm have a written agreement in accordance with NASD Rule 6955 (c) stating that the above referenced organization will report on your firm s behalf? yes no Section 4: Submitter Information (This section must be completed in full.) Printed Name of Submitter Submitter s Phone Number Submitter s Signature Date OATS Subscriber Initiation and Registration Form Page 4 of 6
5 Section 5: Registration Activity Checklist NOTE: Your firm should have prepared a system to report order information to the OATS system using the OATS Reporting Technical Specifications, OATS Subscriber Manual, and OATS Frequently Asked Questions; alternatively, your firm should have contracted with one or more third parties to provide this service. No member firm or third party may transmit data to the OATS production environment unless it has successfully transmitted to the OATS testing environment. If you have questions about transmitting your data to OATS, contact NASD Business and Technology Support Services. Step 1: After filling out this registration form, mail or fax it to Business and Technology Support Services at the location or fax number provided on the first page. The form must be accompanied by a request for an initial user account. This account provides your organization access to the OATS Web interface. The OATS Web interface allows users to create and update OATS Contacts, view FORE file status, reporting statistics, detailed ROE rejections, and order/trade matching statistics; and to request additional user accounts. (For procedures on how to use the Web interface, refer to the OATS Subscriber Manual on the NASD Web Site at This account can also be used for submitting OATS data via . (To submit OATS data via FTP, you must use the OATS Web interface to request an additional FTP user account.) For security reasons, the request for an Initial User Account must be on your organization s letterhead and must contain the following information: Organization Name, Organization Address, Broker Dealer Number (if appropriate), User Name, User Telephone Number, and User Fax Number. If your organization will be submitting to OATS via IFT, you must contact Tumbleweed Communications, contact person: Edmond K. Ng at or at edmond.ng@tumbleweed.com to obtain the software package. Please advise Tumbleweed Communications software is being purchased for NASD purposes. Step 2: A representative from Business and Technology Support Services will contact you and provide the initial User ID and Password and Order Sending Organization (OSO) ID. If your firm is transmitting on its own behalf you will be given a User ID and password for the testing environment only. Your firm will also receive a copy of User Guidelines for Obtaining Production User IDs and Passwords. A Reporting Date will be assigned to your firm and published on the web. Firms must begin transmitting order information to OATS on this date. However, regardless of the Reporting Date assigned to a firm to actually begin reporting electronic submissions to OATS, all NASD member firms must record and retain OATS data beginning the first date they receive an OATS reportable order. Once the firm receives its Reporting Date, all OATS reportable data retained by the firm for orders received prior to that time, must be submitted to OATS. Step 3: After your Initial User Account is set up and required firms have met the testing criteria, you must use the OATS Web interface to enter OATS Contact information for your OSO Administrator, Technical Contact, and Compliance Contact. (Refer to the OATS Subscriber Manual for additional information.) Step 4: If your organization will be submitting to OATS via the private network (i.e., via FTP or CONNECT:Direct), you must submit to SAVVIS a completed order for an OATS circuit. For additional information about obtaining an OATS circuit or an OATS Service Order Package, contact SAVVIS at Organizations that plan to transmit data to OATS in Phase 3 via the private network should submit completed circuit orders and registration forms as soon as possible as circuit orders require approximately 120 days for processing. OATS Subscriber Initiation and Registration Form Page 5 of 6
6 Step 5: Firms must establish OATS Reporting Relationships in both the OATS Testing and OATS Production environments. This provides member firms with control of who submits data on their behalf. If the firm does not establish these Relationships files submitted by the firm, or on its behalf, may be rejected. (Refer to Chapter 6 of the OATS Subscriber Manual for further details.) Step 6: Your firm must begin reporting data to the OATS production environment on your Reporting Date (see Step 2). NOTE: No member firm or third party may transmit data to the OATS production environment unless it has successfully transmitted to the OATS testing environment. For additional information about OATS, this form, or the checklist, contact NASD Business and Technology Support Services via phone at NASD or via at supportservices@nasd.com. Information about OATS is also available from the NASD Web Site ( OATS Subscriber Initiation and Registration Form Page 6 of 6
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