FINRA to Require TRACE Reports on Treasury Transactions

The Securities and Exchange Commission (the “SEC”) has approved the Financial Industry Regulatory Authority’s (“FINRA”) plan to require, as of July 10, 2017, the reporting by FINRA member firms of transactions in U.S. Treasuries to the Trade Reporting and Compliance Engine (“TRACE”).  See FINRA Regulatory Notice 16-39, October 2016, here.  The rules will apply to marketable Treasuries and those that have been separated into principal and interest components pursuant to a Treasury Department program (“STRIPS”).  They will apply to virtually all non-auction transactions, including “when issued” transactions, but not to repos and reverse repos.  In general, each party must report.  Reports of transactions effected at or after midnight through 5 p.m. must be reported same day, and after 5 p.m. on a T + 1 basis.  The reporting details are set forth in the notice and on the FINRA website.