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.
Each member introducing firm is 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 that this CSV file is a one-time submission; a member introducing firm is only required
to submit a subsequent CSV file to update the information previously provided to FINRA.
- CSV files must be submitted within one month after the end of the calendar quarter addressed
in the Rule 606(a) Report that a member introducing firm is adopting by reference. For
example, if an introducing firm adopts a clearing firm’s Rule 606(a) Report by reference for
activity during Q2 2024, such introducing firm will have to submit a CSV file disclosing the
clearing firm relationship by July 31, 2024.
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 introducing firm’s disclosure of its clearing firm relationship(s) .
3.1. How to create a CSV file
The clearing firm relationship CSV file can be created using Microsoft Excel, Notepad,
Notepad++ or similar editor. The below steps describe one way a member firm could create a
clearing firm CSV file using Excel:
- Open a new excel document. The first column (column A or column 1(R1C1 reference
style)) will contain the Clearing Firm CRD. The second column (column B or column 2(R1C1
reference style)) will contain the corresponding disclaimer web link (Note: This is the
weblink where the member introducing firm discloses its clearing firm relationship(s) and
adopts the clearing firm’s reports by reference).
- In row 1, Cell A1, enter the clearing firm CRD number with no additional text. In row 1,
Cell B1, enter the disclaimer weblink for the corresponding firm’s CRD entered in Cell A1.
Cell A2, B2 in row 2 will contain the second clearing firm’s CRD, disclaimer weblink
respectively and so on for subsequent clearing firms.
- Sample Clearing Firm relationship CSV contents:
4567,https://firm123.com/disclaimer-link
1634,https://firm123.com/disclaimer-link
9367,https://firm123.com/disclaimer-link
- Screenshot of sample contents of the Excel document (to be saved in the next step
as a CSV file)