FINRA reminded member firms of their obligation under FINRA Rule 6730 to input accurately the "time of execution" for transactions in their Trade Reporting and Compliance Engine ("TRACE") reports. FINRA specified that the "time of execution" of a transaction in a TRACE-eligible security is generally the time at which the parties to the transaction agree to all of the material terms sufficient to calculate the dollar price of the trade.
To illustrate this point, FINRA specified that the "time of execution" of a transaction is not necessarily the time that the trade information is entered into the firm's processing system, but rather when there is a "meeting of the minds" with regard to the material terms of the transaction.
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