The Financial Industry Regulatory Authority issued guidance that firms must have written procedures addressing how they will deal with over-the-counter trading and reporting of equities during a trading day if they are unable to connect with a FINRA reporting facility for any reason—whether a cause individualized to the firm, or a systemic failure. Under certain circumstances, the procedure should require the firm to cease OTC trading completely. Under FINRA rules, firms must report OTC transactions in equity securities as soon as possible but by no later than 10 seconds following execution.