FINRA Rule 7660B: New TRF Fees for Non-Participant Members

FINRA just filed SR-FINRA-2026-003 with the SEC, proposing new Rule 7660B to establish fees for members who don't use the FINRA/NYSE Trade Reporting Facility for trade reporting but want to purchase certain services from it. This is a narrow rule, but if you're a smaller broker-dealer that's been looking at TRF data services without actually reporting through the facility, it directly affects your cost structure.

What Rule 7660B Does

The proposed rule creates a fee category that didn't exist before. Currently, the FINRA/NYSE TRF fee schedule applies to participants — firms that actually use the facility to report OTC trades in NMS stocks. Rule 7660B would extend a fee structure to non-participants who elect to purchase specified services.

What services? The filing references data and connectivity services that TRF makes available. If your firm isn't a participant but wants access to certain TRF outputs, you'd now be paying under this new fee schedule rather than getting informal access or going without.

Why This Matters Operationally

Most small and mid-sized broker-dealers aren't TRF participants. They clear through correspondents or route orders to executing brokers who handle the trade reporting. That's fine. Nothing about Rule 7660B changes your reporting obligations.

But here's where it gets practical. If your operations team or compliance function has been considering purchasing TRF data for surveillance, reconciliation, or market analysis purposes, you now have a defined cost to factor in. The rule creates transparency around what non-participants pay. That's useful for budgeting.

It also means FINRA is formalizing something that may have been handled informally before. If your firm has been accessing TRF services through some arrangement that didn't involve direct fees, expect that to change once this rule takes effect.

Compliance Considerations

This isn't a supervisory rule. It doesn't change your WSPs or create new compliance obligations. But it does have budget implications that CCOs need to flag for firm leadership:

• Review any existing arrangements for TRF data or services
• Confirm whether your firm is technically a "non-participant" under the rule's definitions
• Factor potential new costs into your 2026 compliance and operations budgets
• Monitor the SEC comment period for any modifications to the fee structure

The Bigger Picture

FINRA has been methodically cleaning up its fee structures across facilities. This filing fits that pattern. The goal is clarity — making sure every firm that uses TRF services, whether as a reporting participant or a data consumer, knows exactly what they're paying for.

For most broker-dealers, this is a line item, not a strategic concern. But if you've been getting TRF services without a clear fee arrangement, that's ending. Budget accordingly.

What to Do Now

Check with your operations team. Do you purchase anything from the FINRA/NYSE TRF? If yes, get clarity on current costs and compare against the proposed fee schedule once it's published in detail. If no, file this away and move on — the rule doesn't affect you.

The SEC will publish the proposed rule for comment. Watch for the final fee amounts and effective date.

Jay Proffitt, Founder and CEO, GiGCXOs