Rule 605 Tech Spec Filing
On June 12, 2025, the SEC released the FINRA technical specifications for Rule 605 reports. The SEC is soliciting public comment on the spec, due 21 days after date of publication in the federal register.
One part in particular stood out to us, on page 5, section V, footnote 2, which states:
A single entity may be required under the Rule to produce separate reports pertaining to different functions and should arrange for a Designated Participant for each such report. An entity that acts as a market maker in different trading venues (e.g., as specialist on an exchange and as an OTC market maker) would be considered as a separate market center under the Rule for each of those trading venues and would be required to publish a separate report for each such market center.
We take this to mean that each floor broker or designated market maker would need to report a 605 separate from their other market making operations’ 605 requirements – they would need to produce a 605 for the customer flow that they internalize, plus one for each of the exchanges they are market makers or specialists. This would significantly increase the number of 605 reports each market maker would need to produce.
Expansion of CAT Support
The 2025 FINRA Annual Regulatory Oversight Report reveals several findings related to CAT reporting, including incomplete submissions, failure to submit corrections, and perhaps most importantly, failure to establish and maintain reasonable supervisory controls. While S3 currently provides unrivaled support for many large firms with full service CAT reporting, we’re developing a new CAT Supervision suite to ensure your supervisory processes are both effective and audit-ready. The foundational tool, CAT Insights, provides a centralized dashboard that simplifies exception management, tracks daily metrics, flags submission issues, and generates supervisory reports. You’ll gain a clear summary view of your reporting with tools to drill into, search, and filter all reportable records and errors. Integrated audit functionality and life cycle views help you quickly identify issues, ensure compliance, and maintain full transparency and oversight.
A beta / pilot version for CAT Insights is launching soon, and we invite early adopters to help to shape the final product while gaining early access to enhanced CAT governance.
Other News
We are proud to announce that six US equity exchanges have chosen to partner with S3 for 605 reporting. The SEC’s updates to Rule 605 add several new layers of complexity and we’re proud to have so many exchanges turn to us for guidance.
We now have full options market data for Canada!
Mark Davies breaks down Best Ex for the global markets in an interview with Global Trading. CLICK HERE