Orders received for foreign securities that are OTC Equity Securities must be reported if any resulting executions are subject to transaction reporting under FINRA Rule 6622. CAT reportable orders for foreign securities that are OTC Equity Securities must be reported to CAT using the US symbol and price in US dollars.

In this example, part of the order is executed over-the-counter in the US by the Industry Member and is therefore subject to transaction reporting under FINRA Rule 6622, and the other part of the order is executed and reported in the foreign market and therefore not subject to transaction reporting under FINRA Rule 6622. Thus, the firm would have an obligation to record and report a New Order event reflecting the receipt of the order, an Order Route event for each component sent abroad, an Order Fulfillment event for the portion executed and reported abroad, and a Trade event for each component executed by the Industry Member in the US.

Refer to FAQ I4 for additional guidance if the market of execution is not known by the end of the CAT Trading day.