General:

Files should include market orders, limit orders, marketable limits, stops, stop limits, cancelled orders and option orders. Trades may be consolidated into a single quarterly file, or separated into monthly files. A detailed record layout must accompany file submissions. Exchanges should include a Specialist ID cross-reference.

File Type:

Fixed record length ASCII (MS-DOS), non-delimited, with one record per line and no headers.

Required Information:

Date order received

Date trade executed (or cancelled)

Order Type (market, limit, stop, stop limit)

Symbol

Time order received*

Time trade executed (or cancelled)*

Order Status (filled, open or cancelled)

Buy or Sell (Customer Side)

Execution price fields (as needed): (1) Execution price (2) Limit price (3) Stop price.

Indicators: (1) GTC/Day (2) All-or-none (3) Fill-or-kill (4) Not held (5)Non-display requested

For files submitted by exchanges only: Specialist ID, Exchange ID, Firm Code, Branch Code, Branch Seq. No.

*Note: Times should include seconds, and be expressed in Eastern Standard/Daylight Time. Additional fields may be included for custom filtering, trade identification, filler, etc.

Field Parameters:
Field length, field placement within record, and individual field formatting are at your discretion.

File Names:
For files submitted by market makers or exchanges:

Format:     MCTRCUST.PSS
"MCTR"  Your 4-digit market participant ID
"CUST"   4-digit market participant ID of RND client firm (i.e. your customer)
"P"           [M]onthly or [Q]uarterly trade file
"SS"         2-digit starting month of trade file (01 through 12)
Example: MCTRCUST.Q07é "CUST" trades executed by "MCTR" for the quarter ("Q") starting in July ("07")

For files submitted directly by RND clients:

Format: MCTRCLNT.PSS
"MCTR" 4-digit market participant ID of market center (or internal desk) being audited
"CLNT" Your 4-digit market participant ID
"P" [M]onthly or [Q]uarterly trade file
"SS" 2-digit starting month of trade file (01 through 12)
Example: MCTRCLNT.Q07é "CLNT" trades executed by "MCTR" for the qurter ("Q") starting in July ("07")

**Note:  4-digit market participant IDs may be replaced with your own 4-digit codes or an RND supplied code.

Optional File Preparation:

Large files may be "zipped" using PKZIP or compatible software to facilitate transmission or storage on diskette.

Delivery of files (please notify us prior to transmission of files):
-Via FTP to SECNASD.COM Floppy disk (3.5) or Iomega ZipDisk.

Trades to be Eliminated

1. Cash Sales & special settlements (cash, next day, or sellers options)
2. Sold sales
3. Market-on-close
4. Day Close
5. Cancels & Corrections
6. Prior date (as of) trades
7. Duplications
8. Off-hours trades
9. "Manual" trades
10. Busted trades
11. Crossing orders
12. Mark-ups
13. ** GTC Market Orders
14. ** Fill-or-kill / Immediate-or-cancel
15. ** All-or-none
16. **Not held orders
** These trades may be included in the file if appropriate indicators are supplied.

Special Notes

1. Be sure trade "side" is from customer's point of view.
2. Be sure execution prices do not include any mark-ups or fees.
3. Be sure receipt times reflect the time of order entry into the trading system.
4. Be sure decimal prices are fully expressed (ie. not rounded to too few places).

Address questions to our systems staff.