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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

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

Date: SEC No.: CRD No.: MPID:

LEI #:

GENERAL INFORMATION

Name of TRF Subscriber (hereinafter “Participant”):

Business Address:

City State: Zipcode:

Business Phone: Fax:

Contact Name: Title:

Phone: Fax:

Email Address:

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 (defined below) 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: (a) is a member in good standing with FINRA and shall be a member in good standing at the time any over-the-counter transaction in an exchange-listed security is reported to the TRF; (b) is empowered with the full right and authority to enter into this agreement and to do all things that will be required by this agreement; (c) will not use the TRF or any service related thereto in any manner which is in violation of the Subscriber Service Agreement, the Uniform Service Bureau/Executing Broker Agreement, or any law or governmental regulation applicable to it; (d) will comply with all laws, rules, regulations and contractual obligations in connection with its use of the Service; (e) is solely responsible for ensuring that all of Participant’s trades are processed correctly; (f) will inform the TRF promptly if at any time it ceases to qualify or reasonably expects that it will cease to qualify as a Retail Participant; and (g) agrees that the TRF may periodically audit the Participant.

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, and to the fullest extent permitted by law, TRF expressly disclaims any and all representations and warranties, express or implied. The TRF does not warrant that the Service will be uninterrupted or error-free. In the event of a failure to submit a trade report to DTCC or FINRA, Participant shall be responsible for the resubmission.

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, damages or loss arising from or relating in any way to this Agreement. TRF’s maximum liability for any direct damages associated with this Agreement is five hundred dollars.

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 acknowledgment of receipt.

In the case of the TRF:

NYSE TRF

Attn: Client Relationship Services

353 N. Clark, 31st Floor

Chicago, IL 60654

crs@nyse.com

In the case of Participant:

email:

11. Governing Law and Jurisdiction. The substantive laws of the State of New York shall govern this Agreement. All claims or disputes arising out of or in connection with this Agreement shall be heard exclusively by any of the federal or state courts of competent jurisdiction located in the Borough of Manhattan, New York City, NY, USA.

12. Waiver. No provision of this Agreement shall be deemed to have been waived by any act or knowledge of either party, but only by a written instrument signed by a duly authorized representative of the party to be bound thereby.

13. Survival. The provisions of this Agreement that, by their nature and content, must survive the completion, rescission, termination or expiration of this Agreement shall so survive and continue to bind the parties.

14. Agreement. This Agreement may be modified only by a written instrument physically executed by a duly authorized representative of each party.

AGREED:

Participant:

By:

Name:

Title:

Date:

TRF:

By:

Name:

Title:

Date:

FINRA TRANSPARENCY SERVICES UNIFORM REPORTING AGREEMENT

This Uniform Reporting Agreement is for use by a FINRA member (“Participant”) to authorize another FINRA member (“Reporting Participant”) to report trades on its behalf to a FINRA facility identified on Attachment A hereto as an “Approved Facility.”

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

2. By executing this Agreement, the undersigned Reporting Participant agrees to report trades to the Approved Facilities on behalf of the Participant and to observe and comply with applicable rules and agreements.

FINRA and the Approved Facilities are third party beneficiaries of this Agreement.

REPORTING PARTICIPANT

Name of Firm

MPID/Reporting Participant Symbol

CRD Number

Signature

Name

Title

Date

PARTICIPANT

Name of Firm

MPID/Participant Symbol

CRD Number

Signature

Name

Title

Date

ATTACHMENT A - APPROVED FACILITIES

Use this attachment to list approved facilities and effective dates.

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

FINRA NYSE TRF Subscriber Service Agreement is a standardized contractual framework used by broker-dealers and ATS participants to register as subscribers to the FINRA/NASDAQ Trade Reporting Facility (TRF) operated for NYSE-listed securities. The agreement defines subscriber obligations, data reporting responsibilities, access levels, fees, and service terms needed to transmit executed trade reports to the TRF. It sets operational and compliance expectations, including recordkeeping and reporting timelines tied to FINRA and SEC rules, and establishes how electronic submissions, access credentials, and audit trails must be managed between the TRF operator and the subscribing firm.

Why a Clear Subscriber Agreement Matters

A Subscriber Service Agreement clarifies reporting obligations, access controls, and liability allocation between the participant and the TRF operator, reducing regulatory risk and operational ambiguity while documenting requirements for timely and accurate trade reporting under FINRA and SEC oversight.

Why a Clear Subscriber Agreement Matters

Who Typically Completes This Agreement

Typical organizations that complete this agreement include broker-dealers, trade reporting desks, and third-party reporting agents.

  • Broker-dealers reporting trades in NYSE-listed securities for regulatory compliance and auditability.
  • Execution venues or ATSs submitting matched trade reports on behalf of clients and counterparties.
  • Third-party vendors and trade reporting agents authorized to file on a subscriber's behalf.

Confirming roles upfront helps ensure correct access, authentication, and fulfillment of FINRA and SEC trade reporting expectations.

Who Signs and What Authority They Hold

Chief Compliance Officer

Typically holds authority to accept regulatory terms on behalf of the firm, confirm reporting protocols, and designate reporting delegates. The CCO must ensure ongoing compliance with FINRA and SEC reporting rules and maintain records for examinations.

Head of Trading

Responsible for operational execution, ensuring trade reporting IDs are applied correctly, supervising trade reconciliation, and coordinating with the compliance team to correct reporting errors promptly and preserve audit trails for regulatory review.

Core Sections to Expect in the Agreement

Core sections of the FINRA NYSE TRF Subscriber Service Agreement define access, reporting obligations, fees, security, compliance, and termination procedures.

Access Rights

Specifies authorized users, account provisioning, multi-factor or token authentication requirements, and limitations on who may submit trade reports to the TRF on the subscriber's behalf.

Reporting Obligations

Outlines types of trades to report, required fields and formats, time windows for submission, error correction procedures, and reconciliation responsibilities with clearing counterparts and regulatory reporting codes.

Fees & Billing

Describes subscription fees, per-report charges if any, invoice cycles, late payment remedies, and procedures for disputed charges or adjustments between subscriber and TRF operator, including billing contact methods.

Security Controls

Specifies encryption standards, access logging, incident notification timelines, responsibilities for maintaining secure credentials, and requirements for retaining audit trails compatible with FINRA or SEC reviews.

Compliance

Affirms adherence to applicable FINRA rules and SEC regulations, describes notice obligations for regulatory inquiries, and sets procedures for compliance audits and corrective action plans.

Termination

Sets termination triggers including breach, failure to report, insolvency, or changes in regulatory authority, plus data return, transition assistance, and survival clauses for key obligations.

Security and Compliance Essentials to Include

In Transit: Encrypts data in transit using TLS 1.2/1.3
At Rest: AES-256 encryption of stored data
Certifications: SOC 2 Type II; ISO 27001; PCI DSS
HIPAA: BAA available for covered entities
ESIGN/UETA: Legal compliance for electronic signatures
Audit Trail: Detailed timestamps, IP, and action log

Step-by-Step: Complete and Submit the Agreement

Stepwise process for completing and submitting the Subscriber Service Agreement to ensure accurate registration and uninterrupted TRF reporting access.

  • 01
    Prepare Info: Gather legal name, EIN/LEI, contact, and reporting IDs.
  • 02
    Complete Form: Populate all required fields and select governing state.
  • 03
    Authorize Signer: Confirm authorized representative signs and dates.
  • 04
    Submit & Retain: Send to TRF operator and keep copies per retention rules.

Recommended Digital Workflow Settings

Suggested online workflow settings for e-submission, authentication, and automated routing when using an eSignature platform with the TRF Subscriber Agreement.

Field Configuration
Signer Authentication Email link plus SMS code; optional KBA for higher assurance
Signature Method Electronic signature with audit trail; PKI if required
Audit Details Capture IP, timestamps, and signer email
Document Retention Store signed PDF and exportable audit record

How Electronic Completion and Transmission Typically Flows

How electronic completion and submission to the TRF typically flow, from drafting the agreement to receipt of confirmation.

  • Upload: Upload agreement PDF to eSignature platform.
  • Place Fields: Insert signature, date, and conditional fields.
  • Authenticate: Send signer link with verification code.
  • Submit to TRF: Export completed file and transmit per TRF protocol.

Platform Capabilities to Confirm Before eSubmission

Platform features to verify for secure e-submission include compliance certifications, integrations, and flexible authentication options.

  • Integrations: Salesforce, NetSuite, Google Workspace supported
  • File Formats: Accepts PDF, DOCX, and HTML
  • Authentication: SMS, email, SSO options

Timelines That Affect Reporting and Compliance

Key filing and reporting timelines that affect obligations under the Subscriber Service Agreement and regulatory reporting duties.

Initial Submission Deadline:

As specified by TRF onboarding; typically immediate after execution.

Trade Reporting Window:

Follow FINRA/SEC timeframes for reporting executions.

Record Retention Start:

Effective date determines retention obligation start.

Audit Response Time:

Respond to inquiries per FINRA timelines promptly.

Renewal Notice:

Contract renewal or fee changes typically require advance notice.

Penalties and Risks of Incorrect or Late Submissions

Reporting Penalties: FINRA and SEC enforcement actions
Reputational Risk: Client trust and broker relationships harmed
Financial Fines: Monetary penalties for late or incorrect reports
Backup Withholding: Incorrect TINs trigger 24% withholding
Contract Termination: Operator may suspend or terminate access
Data Breach Liability: Breach can incur HIPAA, PCI fines

Common Preparation Mistakes to Avoid

  • Omitting exact legal entity names or providing trade reporting identifiers with typographical errors, which causes misrouting and regulatory exceptions requiring manual remediation and potential fines.
  • Failing to specify authentication strength or allowing unverified guest signing, which can undermine attribution of electronic signatures and complicate enforcement under ESIGN/UETA.
  • Neglecting to attach required exhibits such as fee schedules, reporting codes, or contact authorizations, leading to ambiguity and delays during incident response or audits.
  • Relying solely on basic e-sign methods without an audit trail or enhanced authentication when TRF or regulator requires higher evidence levels for certain filings.

Practical Tips for Accurate, Efficient Completion

Best practices to reduce errors, speed onboarding, and maintain compliance when negotiating and executing the Subscriber Service Agreement.

Verify Legal Entity and Identifiers Carefully
Before signing, cross-check the subscriber legal name, EIN or LEI, and reporting IDs against regulatory records. A single character mismatch can prevent TRF onboarding, trigger backup withholding, or cause misattributed trade reports requiring costly remediation.
Designate Authorized Signers and Contacts
List authorized signers with titles and contact details, and keep a current certificate of incumbency. This simplifies verification during audits and reduces delays when access must be suspended or modified after personnel changes.
Use Strong Authentication and Audit Trails
Require multi-factor authentication for account access, enable detailed audit logging for each submission, and retain exportable audit records. These steps support ESIGN/UETA validity, assist in investigations, and meet FINRA/SEC expectations.
Document Change and Termination Processes
Include clear amendment procedures and notice periods for fee changes or termination, and specify data return or destruction obligations. Explicit processes minimize disputes and ensure continuity of reporting during transitions.

Examples: How Organizations Implement the Agreement

Real-world scenarios illustrate how different firms implement the Subscriber Service Agreement and manage TRF reporting responsibilities.

Tech Data

Tech Data standardized execution of TRF subscriber agreements across departments using centralized electronic workflows to ensure consistent compliance controls.

  • Integration reduced manual steps and delays.
  • As a result, Tech Data achieved clearer audit trails, faster signer acknowledgement, and more reliable reconciliation of trade identifiers, which supported regulatory examinations and internal compliance reporting and reduced operational costs associated with manual rework and exception handling.

Fertility Centers of Illinois

Fertility Centers of Illinois adopted e-signatures for subscriber forms and downstream reporting to accelerate patient-related transaction documentation and provider attestations.

  • Mobile signing improved turnaround across staff and patients.
  • This approach maintained HIPAA protections via a BAA, preserved detailed audit logs for regulatory compliance, and allowed the clinic to process agreements remotely without compromising security or incurring significant additional administrative expense.

eSignature Vendor Pricing and Capability Comparison

Vendor pricing and feature comparison for eSignature solutions relevant to completing and distributing the Subscriber Service Agreement.

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 trial No No Yes, limited Yes, limited
Bulk Send Yes Yes Yes Yes No
Audit Trail Yes Yes Yes Yes Yes
HIPAA Compliant Yes Yes Yes No No

Frequently Asked Questions and Troubleshooting

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


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