Answer: (Source: FINRA - ISG)
- 1. The address of the customer at the time of the trade.
- 2. The account title at the time of the trade.
In both scenarios, the account holder information should reflect the information at the time of the transaction.
Answer: (Source: FIF Member) The Blue Sheets process reads and reports the data captured in the customer account profile for the underlying client account (the account where the trade is processed or the “sub” account in the question below).
The primary source of account profile information for DVP accounts is the Omgeo Alert database, so the address and TIN information in Alert is generally what is reported to Blue Sheets for DVP accounts. The Omgeo Alert database is populated by the investment advisor (IA).
Alert will have the title of the underlying account, but often the IA will use their own address as a mailing address. Similarly for the TIN, the IA does not always put the underlying client’s TIN in Alert; they sometimes use their own.
Answer: (Source: FINRA - ISG) “The guidance given by the ISG EBS Group is for the Broker-Dealer code field to be populated with “1” for each trade (transaction) executed on behalf of its broker-dealer client and with “2” for the allocation/offset that identifies the broker-dealer client.”
Answer: (Source: FIF Member) A buy-in is a trade that is done to the street and therefore considered to be reportable. It shouldn’t matter if you are booking it to the customer account or the firm account.
Answer 1: (Source: FIF Member)
CMTA out activity has always proved problematic for everyone when it comes to Blue Sheets.
It is our understanding that the regulators typically Blue Sheet the firm that has received the CMTA in rather than the executing firm. However, a lot of firms do post trade allocation of this activity where the trade clears first at the executing firm and it is CMTA'd via the OCC versus given up at the time of execution.
Both methodologies are acceptable as long as the firm is consistent in its approach. There is really no net amount settlement anyway because the executing firm does not settle the transaction. For that reason, you could argue it should be blank.
Answer 2: (Source: FIF Member)
The specs for Blue Sheets indicate that "Net Amount" represents "the proceeds of sales or cost of purchases after commissions and other charges."
I agree with suggestion #1 above: If the firm that is reporting the execution of the trade on its Blue Sheet is not charging a commission, the reasonable expectation would be to just report net money (i.e., "no commissions involved"). Since the actual "billing" of the customer only occurs at the other firm where the trade clears, it would appear to be a "double counting" of commissions if they were reflected in the Blue Sheet transactions at both firms.
Answer: (Source: FIF Member) You would populate your own MPID since you are the broker-dealer behind the submitting broker-dealer. You would also populate your MPID on the Primary ID associated with those executions.