On March 1, 2000, firms were notified of a modification to Exchange policy regarding the reporting of large transfers.  Prior to that date, all transfers were required to be reported at original trade date and price.  In an effort to minimize the processing costs and burdens when clearing firms consolidate their business vis-à-vis large transfers, the policy was amended as follows: 

            In the event of the transfer of all, or a significant portion, of a firm’s open positions to another firm, clearing firms may report the transfer to the clearing system at the prior day’s settlement price and date.  For regulatory purposes, however, firms must maintain complete records indicating each account’s original trade price and date for all positions.

              As such, policy relating to other transfers detailed in Rule 853 (“Transfers of Trades”) remains unchanged.

            Ordinary account transfers related to the correction of clerical errors or misallocation must continue to be reported according to the current policy – at original trade price and trade date.  With respect to options transfers, firms will still have the option to report zero as the premium trade price.

If you have any questions regarding the regulatory requirements of this new policy, please call Eric Wolff, Managing Director, Regulatory Division, at (312) 930-3255.  If you have other questions relating to this policy change, please call Steve Staszak, Director, Operations, Clearing House Department, at (312) 930-3189.