3. File Upload Specifications: Introducing Firm Clearing Firm Relationship
The following section contains reporting requirements for member introducing firms that, pursuant
to existing SEC guidance, route all their customer orders to one or more clearing firms for further
routing and execution and adopt such clearing firm’s Rule 606(a) reports by reference.
These member introducing firms are required to (i) submit to FINRA a comma separated values (CSV)
file that lists its clearing firm(s) along with a web link to a webpage where the member introducing
firm discloses its clearing firm relationship(s) and adopts the clearing firm’s reports by reference and
(ii) update the submission if the information previously provided changes. Please note, this CSV is a
one-time submission, only requiring subsequent file submission in case a member introducing firm
needs to update the information previously provided to FINRA.
This CSV file submission will be subject to the same publication requirement as Rule 606(a) report
submissions, i.e., the CSV file must be submitted within one month after the end of the calendar
quarter addressed in the report.
While the clearing firms will have to submit Rule 606(a) reports to FINRA, the introducing firms are
responsible for ensuring proper and timely submission of said reports.
The clearing firm relationship CSV file must contain the following details:
- CSV file name format
o Intro firm crd number_606_NMS_ clearing_Firm_Details.csv
▪ Sample file name: 12345_606_NMS_clearing_Firm_Details.csv
- CSV Required fields.
o clearing Firm CRD
o Weblink to the intro firm clearing firm relationship.
Sample Clearing Firm relationship CSV contents:
4567,https://firm123.com/disclaimer-link
1634,https://firm123.com/disclaimer-link
9367,https://firm123.com/disclaimer-link