The Financial Information Forum ("FIF") highlighted several challenges and questions regarding amendments to Regulation NMS Rule 606(b), which require broker-dealers ("BDs") to generate on-demand customer reports regarding the order handling of customers' orders, including a "standardized set of individual disclosures."
In a letter to the SEC, the FIF identified challenges that BDs will have in meeting the May 20, 2019 compliance date, including requiring introducing brokers to "obtain and report downstream order execution data." The FIF asserted that many of the requirements may call for BDs to "undergo significant operational, business and technological changes." The FIF also stated that there is significant industry uncertainty regarding the scope of the amendment, and recommended that the SEC clarify a number of key definitions.
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