If your firm operates as both a broker-dealer and an investment adviser under one roof, you already know the reporting headache that comes with executing a single aggregate bond order and then allocating pieces of it across dozens of managed customer accounts. Under the current rule, every one of those allocations gets reported to TRACE separately, even though they all trade at the same price and the same moment. Regulatory Notice 25-17 gives dual BD/IA firms an optional way out of that repetition, effective June 8, 2026.
How the streamlined reporting works
New Supplementary Material .08 to Rule 6730 lets a firm that operates as both a broker-dealer and an investment adviser report the allocation of an aggregate order to multiple managed customer accounts as a single, aggregated TRACE trade report — instead of filing a separate report for every account that received a slice of the trade.
- The allocations have to match. All the allocations bundled into one aggregate report must reflect the same price and the same time of execution, and the report still has to hit TRACE within the normal timeframes under Rule 6730(a).
- The account count gets reported, not the account details. The aggregate report must include the number of managed customer accounts the security was allocated to, under new Rule 6730(c)(14) — FINRA will disseminate that count along with the aggregate volume, subject to existing transaction-size caps.
- It's optional. A firm can keep reporting allocations individually if that fits its systems better, or switch to aggregate reporting where it doesn't. Nothing requires the change.
FINRA illustrates the mechanic with a simple example: a BD/IA buys $5 million (par value) in bonds from the Street, then allocates $250,000 each to 20 managed accounts at the same price with no markup or commission. Under the streamlined alternative, the firm reports the initial $5 million purchase as it always has, then reports the allocation to the 20 accounts as one aggregate trade report showing 20 as the account count — rather than 20 separate reports.
How Compliers Can Help
We help dual-registrant firms evaluate whether a reporting change like this is worth building into existing trade reporting systems, and we support the operational and supervisory updates that come with it. See our Consulting & Staffing page.
One thing that didn't change
FINRA also used this notice to confirm what it's not doing: after engagement with firms, FINRA is not moving forward with a previously approved plan to cut the TRACE reporting outer limit from 15 minutes down to one minute. That earlier change had been approved under a separate rule filing, but firms raised enough concerns during FINRA's follow-up engagement that FINRA is keeping the current 15-minute reporting window in place. If your firm had already started building toward a one-minute reporting standard, that build-out is no longer necessary — the 15-minute standard remains the rule.
For dual BD/IA firms with high allocation volumes, the aggregate reporting option is a genuine operational simplification, but it's worth confirming with your trade reporting vendor or internal systems team whether adopting it actually reduces work, or whether the reconciliation involved in tracking which allocations qualify for aggregation ends up offsetting the reporting savings.