The origination or receipt of an order involving any security that meets the definition of an NMS security pursuant to SEC Rule 600 must be reported to the CAT, regardless of where the order is ultimately executed. This includes any NMS security that is also listed on a foreign exchange (“dually listed”). If the order is sent to a foreign market for execution, the CAT Reporter is required to report the relevant Reportable Events for the order (e.g., origination or receipt of the order and the routing of the order to the foreign market). All prices must be converted into U.S. dollars based on the conversion rate applicable at the time of the transaction.

Orders in foreign securities that are OTC Equity Securities are required to be reported to the CAT where the resulting execution is subject to transaction reporting under FINRA Rule 6622. Pursuant to FINRA Rule 6622(g), the following transactions in foreign securities that are OTC Equity Securities are not reportable: (1) the transaction is executed on and reported to a foreign securities exchange; or (2) the transaction is executed over-the-counter in a foreign country and reported to the regulator of securities markets of that country. CAT reportable orders in foreign securities that are OTC Equity Securities must be reported to CAT using the US symbol, and all prices must be converted into U.S. dollars based on the conversion rate applicable at the time of the transaction.