FINRA Reminds Members of NSCC 9A/9B Requirements Ahead of 24x5 Trading Rollout

Key Takeaways

• FINRA has reissued a reminder about NSCC's requirement for firms to establish separate 9A/9B trading relationships to support overnight trade clearing under the industry's 24x5 trading initiative.
• While FINRA itself is not mandating changes to Uniform Reporting Agreements, firms that fail to meet NSCC's requirements risk having overnight trades accepted at the TRF but rejected at NSCC, creating a trade break and operational/settlement risk.

Deep Dive

This Technical Notice serves as a critical reminder for FINRA member firms participating in overnight (post-8 p.m. ET) trading as part of the broader industry move toward 24x5 markets. NSCC expanded its operating hours on June 28, 2026, and FINRA's Trade Reporting Facilities (TRFs) will extend to 23x5 trade reporting hours starting December 6, 2026, with a one-hour nightly technical pause at 8 p.m. ET. This extension aligns with planned SIP Plan amendments also targeted for December 6, 2026.

The core compliance issue is NSCC's requirement that firms using Correspondent Clearing (CORR) or Qualified Special Representative (QSR) arrangements must establish separate 9A/9B trading relationships specifically for the new overnight session, distinct from their existing daytime relationships. This is established through the Automated Special Representative Facility. Notably, this is an NSCC requirement, not a FINRA rule, and FINRA has explicitly declined to require updates to Uniform Reporting Agreements (URAs). This creates a bifurcated compliance landscape where firms must satisfy NSCC's clearing infrastructure requirements independently of FINRA's reporting framework.

The key risk highlighted is a potential clearing gap: trades may be successfully reported to and accepted by a TRF, but if the corresponding 9A/9B overnight relationship has not been established with NSCC, those same trades will be rejected at the clearing level. This creates a scenario where trades appear compliant from a reporting perspective but fail downstream at clearing, potentially resulting in unmatched trades, settlement failures, or manual remediation efforts. Firms using AGU (Average Price/Give-Up) clearing arrangements are not subject to this particular validation, which is a useful carve-out for firms to note when assessing applicability.

Compliance and operations teams should immediately confirm whether their firm engages in or plans to engage in overnight trading via CORR or QSR relationships and, if so, verify that separate 9A/9B agreements have been established for the overnight session well ahead of the December 6, 2026 TRF extension deadline. Firms should coordinate with their clearing brokers and correspondents, review the DTCC Trade Processing FAQs (particularly FAQ #4), and engage NSCC's Integration Team with any outstanding questions. Given the operational nature of this gap (reporting vs. clearing mismatch), this is primarily an operational and trade settlement risk rather than a regulatory enforcement risk, but failure to act could result in significant post-trade reconciliation burdens and counterparty disputes once overnight trading volumes increase.

Source: Financial Industry Regulatory Authority