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FINRA NYSE TRF Subscriber Service Agreement

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FINRA/NYSE Trade Reporting Facility (TRF) Subscriber Service Agreement - Retail Participants

Revised March 2020

FINRA/NYSE TRF APPLICATION PROCESS

Checklist:

The TRF Applicant must complete and submit all applicable materials addressed in the Application checklist below:

Please submit via email to: crs@nyse.com

Note: All application materials sent to the TRF will be reviewed for completeness by NYSE's Client Relationship Services Department on behalf of the TRF. Applicants may be requested to submit documentation in addition to what is listed in the Application Checklist during the application review process, if necessary. All applications are deemed confidential and are handled in a secure environment at the NYSE and TRF but will also be disclosed to FINRA Operations in order for the subscriber MPID and relationships to be set up for trade reporting. If you have questions on completing the application, you may direct them to: Client Relationship Services: crs@nyse.com or (212) 896-2830, Option 4.

Required Documents:

• Organizational Profile

• Participant Application Agreement for TRF Services

• Uniform Service Bureau / Executing Broker Agreement (If applicable)

ORGANIZATIONAL PROFILE

GENERAL INFORMATION

TYPE OF ORGANIZATION

TYPE OF BUSINESS ACTIVITY TO BE CONDUCTED WITH TRF (Check all that apply)

FINRA MEMBERSHIP CONFIRMATION

CONFIRMATION OF QUALIFICATION AS A RETAIL PARTICIPANT

PARTICIPANT APPLICATION AGREEMENT -- RETAIL PARTICIPANT

THIS PARTICIPANT APPLICANT AGREEMENT is made between the FINRA/NYSE Trade Reporting Facility LLC (hereinafter the “TRF”) and the Participant identified below. This Agreement contains certain Participant information required by the TRF to permit Participant to report over-the-counter trades in exchange-listed securities to the TRF.

NOW, THEREFORE, for valuable consideration, the receipt and adequacy of which are hereby acknowledged, the Participant and TRF hereby agree as follows:

1. Participant Representations. Participant represents and warrants that it: ...

2. Clearing Arrangements. Participant represents and warrants that it has executed a clearing agreement with (“Clearing Broker”).

3. Responsibility for Trades. Participant is responsible for the accuracy and completeness of all information reported to the TRF and agrees to accept and settle all trades that have been reported to the TRF by or on behalf of Participant.

4. Disclaimer. THE SERVICE AND ANY INFORMATION PROVIDED BY THE TRF IN CONNECTION THEREWITH IS PROVIDED ON AN "AS IS" BASIS...

5. Limitation of Liability. IN NO EVENT SHALL TRF, FINRA, OR ANY OF THEIR RESPECTIVE OFFICERS, AGENTS, EMPLOYEES, OR INDEPENDENT CONTRACTORS BE RESPONSIBLE OR LIABLE FOR ANY EXPENSE...

6. Confidentiality. Participant shall keep the terms of this Agreement and information obtained in connection with its use of the Service confidential; except that Participant may disclose such confidential information to a counterparty, regulator, counsel or its agents if required.

7. Suspension of Service. Without waiving any other rights, TRF may at its sole discretion suspend the Service immediately and without notice to Participant if TRF reasonably believes that Participant has breached this Agreement or any other agreement with TRF.

8. Term and Termination. This Agreement shall remain in effect until terminated in accordance with this Section 8. Either party may terminate this Agreement upon thirty days written notice to the other. TRF may immediately terminate this Agreement in the event that Participant breaches a material obligation hereunder.

9. Assignment. Participant may not assign this Agreement or any of its rights or interests hereunder, nor delegate any obligation to be performed hereunder, without the prior written consent of TRF.

10. Notice. Except as otherwise provided in this Agreement, all notices to the parties must be sent by courier, certified mail, or e-mail with acknowledgement of receipt.

AGREED - PARTICIPANT

AGREED - TRF

FINRA TRANSPARENCY SERVICES UNIFORM EXECUTING BROKER AGREEMENT

This Uniform Executing Broker Agreement is for use by a FINRA member participating in one or more FINRA market transparency facilities to authorize another FINRA member to report trades on behalf of the Participant on such facilities.

1. By executing this Agreement, the undersigned Participant hereby authorizes the Executing Broker identified below to add to or delete from the list of Approved Facilities and accepts and approves all trade reports submitted on the Participant's behalf.

2. By executing this Agreement, the undersigned Executing Broker agrees to report to the Approved Facilities all give-up or other trades and comply with applicable rules.

EXECUTING BROKER

PARTICIPANT

ATTACHMENT A - APPROVED FACILITIES

The table on page 8 lists approved facilities including Alternative Display Facility (ADF), TRACE, ORF, FINRA/Nasdaq TRF Carteret, FINRA/Nasdaq TRF Chicago, and FINRA/NYSE TRF.

NAME OF APPROVED FACILITY DATE EFFECTIVE MPID OF EXECUTING BROKER MPID OF PARTICIPANT
Alternative Display Facility (ADF)
Trade Reporting and Compliance Engine (TRACE)
OTC Reporting Facility (ORF)
FINRA/Nasdaq Trade Reporting Facility (FINRA/Nasdaq TRF) Carteret
FINRA/Nasdaq Trade Reporting Facility (FINRA/Nasdaq TRF) Chicago
FINRA/NYSE Trade Reporting Facility (FINRA/NYSE TRF)
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What the FINRA NYSE TRF Subscriber Service Agreement is

The FINRA NYSE TRF Subscriber Service Agreement is a formal contract between a reporting firm and the NYSE Trade Reporting Facility (TRF) operator that defines access, reporting responsibilities, data transmission protocols, fees, and service levels for trade reporting of over-the-counter and exchange-listed securities. The agreement specifies subscriber obligations for accurate reporting, connectivity and message formats, surveillance and audit access, confidentiality terms, and termination or suspension conditions. It also outlines support escalation, regulatory cooperation, and change management procedures necessary to maintain compliance with FINRA reporting rules.

Why this agreement matters to your firm

The FINRA NYSE TRF Subscriber Service Agreement clarifies operational responsibilities, allocates risk, and establishes reporting standards so firms meet FINRA trade reporting obligations. Clear terms reduce reporting errors, speed dispute resolution, and document escalation paths between the subscriber and the TRF operator.

Why this agreement matters to your firm

Typical subscribers and internal stakeholders

Firms that submit consolidated trade reports and clearing firms use this agreement to define reporting and connectivity responsibilities with the TRF.

  • Broker-dealers that submit off-exchange and reported trades to the TRF and interact with FINRA surveillance.
  • Clearing firms handling post-trade allocation, settlement reporting, and exception handling on behalf of clients.
  • Market makers and proprietary trading desks required to meet time-stamped reporting and audit trail obligations.

Transactions routed through the NYSE TRF, alternative trading systems, or inter-dealer networks commonly fall under the agreement's scope.

Key roles who prepare or sign the agreement

Chief Compliance Officer

Responsible for ensuring reporting timelines, accuracy of trade data, regulatory disclosures, and oversight of controls; typically approves subscriber policies, coordinates FINRA interactions, and manages remediation when reporting exceptions or surveillance inquiries arise.

Operations Director

Oversees system connectivity, message formatting, operational runbooks, vendor integrations, monitoring of message throughput, incident response, and daily reconciliation processes to prevent reporting gaps and ensure end-to-end trade lifecycle integrity.

Security and compliance baseline to expect

Encryption: TLS 1.2/1.3 in transit
Data at Rest: AES-256 encryption with key management
Audit Trail: Detailed timestamps, IP and action log
Access Controls: Role-based access and MFA
Certifications: SOC 2 Type II and ISO 27001
HIPAA: BAA available for protected health information

Principal penalties and operational risks

Reporting Fines: FINRA sanctions and monetary penalties
Operational Suspension: Temporary trade reporting suspension possible
Data Reconciliation: Settlement failures and downstream exceptions
Regulatory Inquiries: Examinations, subpoenas, and document requests
Contract Termination: Service termination for material breach
Reputational Risk: Market trust erosion and client loss

Common preparation mistakes to avoid

  • Incomplete or improperly formatted trade messages that do not conform to TRF protocol cause rejects and increase reconciliation workload with clearing firms.
  • Mismatched legal entity names or missing taxpayer identification can trigger backup withholding or delay regulatory filings for reportable transactions.
  • Failing to maintain secure audit trails and retention policies risks noncompliance with SEC and FINRA recordkeeping rules during examinations.
  • Using informal electronic signatures without documented consent or consumer disclosure may be problematic for consumer-facing financial records under ESIGN.

Core contract elements to confirm before signing

A professional agreement addresses access rights, reporting obligations, confidentiality, fees, audit rights, and change control procedures required for compliant trade reporting operations.

Access Rights

Defines permitted users, connectivity methods, messaging formats, hours of access, and any interoperability requirements with third-party order management or execution systems; includes procedures for adding or removing authorized accounts.

Reporting Obligations

Specifies which trades must be reported, reporting timelines, data fields required, error correction procedures, and responsibilities for split allocations or late submission reconciliations with counterparties and clearing agents.

Fees

Details subscription fees, per-message or per-report charges, fee review periods, billing cycles, and conditions for fee adjustments or dispute resolution related to invoicing errors and late-payment interest terms.

Audit & Inspection

Grants TRF operator and regulators inspection rights, specifies acceptable audit data exports, retention windows for logs, obligations for remediation of findings, and procedures for responding to regulatory subpoenas.

Confidentiality

Defines confidential information categories, permitted disclosures for regulatory compliance, obligations to protect market-sensitive data, breach notification timelines, and exceptions such as lawful government requests and vendor data-sharing controls.

Change Control

Outlines notice periods for protocol updates, testing windows, rollback procedures, responsibilities for software upgrades, and coordination for emergency patches that might affect reporting accuracy or connectivity.

Step-by-step: preparing and executing the agreement

Follow this sequence to prepare, review, and execute the subscriber agreement with accuracy and regulatory compliance.

  • 01
    Prepare: Collect legal names, TINs, and authorized signer details.
  • 02
    Populate: Complete reporting parameters, connectivity endpoints, and messaging formats.
  • 03
    Review: Legal, compliance, and operations teams must sign off.
  • 04
    Execute: Obtain authorized signatures and retain executed copies.

How to configure an online signing workflow

Configure electronic workflow settings to match reporting cadence, signer order, authentication methods, and audit requirements before submission to the TRF.

Field Configuration | Recommended Value
Signer Order Sequential | Operations then Compliance
Authentication Email link | SMS OTP or KBA optional
Bulk Send Enabled | Use for high-volume reports
Audit Trail Enabled | Capture IP, timestamp, activity log

Submission and routing workflow overview

Routing and submission flow for executing the agreement and establishing reporting connectivity with the TRF operator.

  • Upload Document: Upload executed agreement to vendor portal or secure repository.
  • Assign Signers: Add authorized signers and set signing order.
  • Authenticate: Use email, SMS OTP, or stronger KBA.
  • Archive: Store signed copies with audit trail for retention.

Technical and integration prerequisites

Technical prerequisites and integrations to support e-signature, secure storage, and connectivity to reporting systems and vendor APIs.

  • Supported Formats: PDF, DOCX, and XML payloads supported
  • Integrations: Salesforce, NetSuite, Google Workspace, Box
  • Authentication: SSO, SAML, OAuth supported

How the TRF subscriber agreement differs from other reporting agreements

Quick comparison between the NYSE TRF Subscriber Service Agreement and adjacent reporting agreements to clarify reporting scope and obligations.

Criteria TRF Agreement FINRA Direct Reporting
Reporting scope trf trade submission direct finra submission
Connectivity sip/api endpoints fix/api or proprietary
Fee model subscription or per-message member-based fees
Audit access operator and finra finra only

eSignature vendor pricing and feature snapshot for executing agreements

Basic vendor pricing and feature comparison for eSignature solutions commonly used to execute and manage subscriber agreements and regulatory forms.

signNow DocuSign Adobe Sign PandaDoc HelloSign
Starting Price $8/user/mo $15/user/mo $14/user/mo $19/user/mo $15/user/mo
Free Trial Yes, 7-day free trial Varies by promotion Varies by promotion Varies by plan Varies by promotion
Bulk Send Yes Yes Yes Yes No
Audit Trail Yes Yes Yes Yes Yes
HIPAA Compliant Yes Yes Yes No No
Envelope Cap No envelope cap 100 envelopes/user/year Varies by plan Varies by plan Varies by plan

Key procedural deadlines to track

Key deadlines relevant to reporting, tax withholding, and regulatory submissions when executing or updating the subscriber agreement.

Provide W-9 on request:

Furnish payer-requested W-9 promptly to avoid backup withholding.

Update contact details promptly:

Notify operator within agreed notice period to avoid missed notices.

Respond to audits:

Produce requested records within regulatory timeframes during examinations.

Reportable changes:

Amend connectivity endpoints before go-live or scheduled maintenance.

Annual review:

Conduct contractual and technical reviews at least annually.

Operational flow for executing and enabling reporting

Routing and submission flow for executing the agreement and establishing reporting connectivity with the TRF operator.

  • Upload Document: Upload executed agreement to vendor portal or secure repository.
  • Assign Signers: Add authorized signers and set signing order.
  • Authenticate: Use email, SMS OTP, or stronger KBA.
  • Archive: Store signed copies with audit trail for retention.

Practical steps to improve accuracy and speed

Adopt these practices to reduce errors, accelerate signings, and maintain compliance throughout the subscriber agreement lifecycle.

Standardize templates with field validation rules
Use a single approved template with enforced field validation to prevent formatting errors. Implement conditional fields for variant clauses, and require dual review by legal and compliance before distribution to avoid inconsistent terms that delay execution and regulatory acceptance.
Confirm signer authority and documentation
Verify signing authority through corporate resolutions or power of attorney documents before accepting signatures. Record evidence of authority with the signed agreement and retain it per retention schedules to streamline audits and defend against challenges to execution validity.
Use secure authentication levels appropriate
Apply authentication strength proportional to risk: simple email for internal administrative updates, SMS OTP or SSO for standard signings, and KBA or multi-factor for high-value or regulatory-sensitive signings. Document authentication choices to support attribution.
Maintain audit trails and perform reconciliations
Capture complete audit logs including IP, timestamp, and action details for every signing event. Schedule routine reconciliations between TRF reports and internal trade records to detect mismatches early and correct reporting errors before regulatory review.

Real-world examples of eSignature at work

Two brief examples show how organizations used eSignature and integration to streamline execution and compliance.

Tech Data

Tech Data integrated signNow to streamline contract circulation and approvals across internal teams and external partners.

  • Result: faster processing and fewer manual steps.
  • By centralizing execution and maintaining secure audit trails, Tech Data reduced administrative bottlenecks, ensured consistent compliance with recordkeeping obligations, and shortened revenue recognition timelines while retaining defensible evidence for audits and regulator inquiries.

Xerox

Xerox used signNow integrated with NetSuite to manage signature workflows for high-volume operational documents and compliance coordination.

  • Flexibility improved processing and turnaround times.
  • Integration reduced manual data entry, allowed role-based signing order, and preserved detailed audit logs to satisfy corporate governance and regulator requests while enabling teams to close workflows without in-person meetings or paper routing.

Key milestones from negotiation to ongoing maintenance

Milestones from negotiation through operational reporting activation and ongoing maintenance for the subscriber agreement.

01

Negotiation & Terms

Define scope, fees, and SLAs before signature.

02

Implementation & Testing

Provision endpoints, run sandbox tests, verify messages.

03

Go-Live & Monitoring

Enable production reporting and monitor for exceptions.

04

Ongoing Review

Annual contract and technical reviews, audit readiness checks.

Frequently asked questions about execution and compliance

Answers to common questions about completing, signing, and retaining the FINRA NYSE TRF Subscriber Service Agreement.


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