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FINRA found that a system configuration error caused Merrill Lynch to, among other things, inaccurately report millions of trades to a FINRA Trade Reporting Facility in which purchases were reported as principal sales and agency crosses.
It also suggested specific flags that should be used to identify types of trade, including benchmark trades, agency crosses, give-up/give-in trades, dark trades and negotiated trades.
Possible options for improving the quality of OTC trade reporting include better flagging of post-trade executions to highlight different types of trades such as agency crosses, guaranteed VWAP trades and internal transfers, and stripping out types of execution that are largely considered unnecessary.
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