Electronic Blue Sheets (EBS) Q&A

Answer: According to the ISG, a trade in a foreign currency must be translated to USD. 

FINRA FAQ 16: For trades executed in a foreign currency, what exchange rate should be used to translate the trade price into U.S. dollars? Is it acceptable to use the noon buying rate used by the Federal Reserve? 

FINRA Answer 16: The use of the Federal Reserve noon buying rate is acceptable. The firm may use an alternative foreign exchange rate, as long as any such exchange rate used is applied consistently in all EBS reporting by the firm.

Answer:  Yes. See FINRA FAQ 9 and FINRA FAQ10 

FINRA FAQ 9: How should securities without U.S. symbols be handled? Are they out of scope for EBS requests? 

FINRA Answer 9: Non-U.S. securities are not out of the scope of EBS requests. When the U.S. security is traded in a non-U.S. market, the ISG wants to see the U.S. symbol. When the U.S. security is an American Depository Receipt (ADR) or American Depository Share (ADS) and the ISG participant is also interested in the home country or “Ordinary” shares, the ISG participant will send two distinct EBS requests, one for the ADR or ADS, and one for the Ordinary shares. In this event, the firm should report the Ordinary symbol and the corresponding non-U.S. identification number. 

FINRA FAQ 10: Since there is no OPRA ticker symbol for foreign options, does that mean they are out of scope? 

FINRA A10: No, foreign ISG members could request information through the ISG. Therefore, foreign securities could be requested, and therefore EBS must be reported.

Answer: (Source: FIF Member) Following is an example of how to populate the Prime Broker field on Electronic Blue Sheets. 

Customer = Big Fund 
Customer’s Prime Broker = PB Firm (1234) 
Executing Firm = EX Firm (1111) 

“EX Firm” (1111) executes a trade for “Big Fund”. 
The contra party to the trade is “CP Firm” (9999). 

Submitting Broker = “EX Firm” 1111 
Opposing Broker = “CP Firm” 9999 
Prime Broker = “PB Firm” 1234 

ISG isn’t looking for the Contra Party’s Prime; it is the Customer’s Prime (if they aren’t primed with you) they are interested in. This has always been an “enter it if your system knows it” type of field. 

The Executing Firm will also appear on Blue Sheets in the Primary Party Identifier (PPI) field. 

The allocation question doesn’t seem to apply because by definition, the Prime would be doing subsequent allocations, and so the non-Prime firm (who would be the only one to submit Blue Sheets with “prime” populated) would have no view into subsequent allocations.

Answer: (Source: FINRA - ISG) If any of the transaction type codes are required when trade reporting a fixed income product, then it should also be reflected in their Blue Sheet reporting. 

Answer: (Source: FIF Member) No, exercises and assignments are not Blue Sheet reportable. They are not trades; they are more akin to corporate actions.

Answer: (Source: FIF Members) 

Firm #1: We believe that the settlement ‘transaction’ is simply reflecting the movement of shares. It is not a true trade and therefore not reportable to Blue Sheets. 

Firm #2: We report the primary transaction, but then would consider this a ‘clearing move’. It is booked as a sell, but it is really a delivery, and would not report it to Blue Sheets.

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