The SEC’s “large trader” rules that apply to clearing firms and certain other firms will kick in this November. Thanks to a recent SEC release, some firms are getting a two-year compliance reprieve, but they must develop the procedures and systems for reporting large trader activity within those two years.
The SEC originally established two phases for implementing broker-dealers’ obligations. The recent SEC release now limits the scope of the obligations under the second phase of the rollout, and creates a third phase that delays the remaining obligations under the rule. The SEC’s revised timetable resulted from a request by industry organizations that highlighted implementation challenges related to the recordkeeping and reporting requirements and, in particular, the requirement that the broker-dealers obtain and report the execution times of large traders’ transactions.
For more information, please see our client alert.