In order to ensure that customer orders are transmitted to the marketplace in a timely manner, FINRA developed the Order Audit Trail System (OATS). The OATS system tracks an order through each stage of its life from receipt to execution or cancellation. Each firm is required to synchronize clocks used for time stamping and reporting daily to the National Institute of Standardized Time’s atomic clock to within 3 seconds and must display military time in hours, minutes and seconds as 00:00:00.

Firms are required to submit daily electronic OATS reports to FINRA. OATS reports must be made the same day an order was received or on the day information becomes available to the firm. Daily electronic OATS reports can be made for single or multiple orders. Information collected on the OATS report includes:

  • Customer or firm order
  • Date and time of receipt
  • Order ID
  • Terms of the order (i.e. buy, sell, sell short, security, price, shares, account type and handling instructions)
  • If the order was received manually or electronically
  • If the order was routed manually or electronically
  • Where the order was routed for execution
  • If the order was an intermarket sweep order
  • Any modifications to the order including the date and time of any modifications
  • Execution information including partial executions, price, date, time and capacity in which the firm acted in the trade

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