The Financial Industry Regulatory Authority (FINRA) issued a Regulatory Notice (07-46) encouraging comment on two recent FINRA proposals to amend current over-the-counter (OTC) trade reporting requirements for equity securities transactions. The first proposal acknowledges that the current reporting structure may result in “confusion, delays and double reporting,” and sets out two potential reporting alternatives to address the problem: (i) a strict sell-side reporting structure (i.e., the sell-side always has the trade reporting obligation); or (ii) an executing broker reporting structure (i.e., the broker executing the trade always has the reporting obligation). The second proposal considers requiring firms to include a unique identifier on tape reports and clearing only reports related to the same overall transaction. Comments on the proposals must be submitted by November 12.