FINRA Alerts Members to NSCC Requirements for Overnight Trading Session

FINRA alerted member firms that use its Trade Reporting Facilities ("TRFs") about new National Securities Clearing Corporation ("NSCC") requirements for the overnight trading session.

In a Technical Notice, FINRA reminded firms that its TRFs scheduled an extension of operating hours to support 23x5 trade reporting, starting December 6, 2026 (see prior coverage). As part of the same industry-wide initiative, NSCC expanded its own operating hours in June 2026 to support 24x5 trade processing.

According to the notice, NSCC requires members with Correspondent Clearing or Qualified Special Representative ("QSR") relationships who want to participate in overnight trading to establish and maintain separate relationships for the overnight session, which can be established through the Automated Special Representative Facility. FINRA emphasized that this is an NSCC requirement, not a FINRA requirement. FINRA clarified that it does not require firms to amend their Uniform Reporting Agreements for overnight trade reporting. However, FINRA warned that firms that do not update their 9A/9B agreements for the overnight session risk a mismatch in which QSR clearing trades are reported to and accepted at a TRF but rejected at NSCC. The notice adds that NSCC parent DTCC's 9A/9B trading relationship validations do not apply to Automated Give-Up clearing trades.