Are all odd lot transactions required to be appended with the .RO modifier?
A. No. Only those odd lot transactions that are subject to a Section 3 fee are to be appended with the .RO modifier. If an odd lot transaction is not subject to an NASD Section 3 Regulatory Transaction Fee (e.g., the second leg of a riskless principal transaction), the .RO modifier should not be appended to the transaction report. As firms will be assessed an NASD Section 3 Regulatory Transaction Fee on any transaction reported with a .R modifier, firms must ensure that only those transactions subject to an NASD Section 3 Regulatory Transaction Fee are reported with such a modifier. Q. If an odd lot transaction was required to be reported to an NASD trade reporting system prior to December 1, 2006 pursuant to another NASD trade reporting rule and such rule requires a modifier other than the .RO (e.g., .W) to be appended to the transaction report, which modifier should be appended? A. In general, odd lots that are not otherwise required to be reported to an NASD trade reporting system e
