On May 17, 2005, the AMEX completed the rollout of new BARS enhancements, including the new "Order Ticket" functionality that allows BARS users to create a time-stamped handwritten JPEG of an order to facilitate systematizing of orders immediately upon receipt. However, in order to use this Order Ticket enhancement in compliance with the Consolidated Options Audit Trail System ("COATS") obligations as well as Amex Rule 153, Commentary .01, all the following information must be recorded on the JPEG Order Ticket prior to representation:
It is mandatory that all required information, as specified above, be included on the Order Ticket prior to representation of the order. Failure to do so could result in disciplinary action as appropriate.
- Call/Put (calls are assumed unless "P" is written)
- Strike (fractions are assumed, e.g., "22 ½ " should be written as "22")
- Price term (a limit order is assumed if a price is written, e.g., "1.20" means a 1.20 limit. Market orders are blank or represented by a dash)
- Contingencies (if applicable, e.g., NH, AON, FOK, IOC)
- Open/Close (close is assumed unless "O" is written)
- Customer/Firm/Member Market Maker/Non-Member Market Maker (customer is assumed unless "F", "P" or "N" is written.)
At the first mark on the Order Ticket image, the Exchange's systems will automatically time stamp the ticket with a "Create Time". When a broker or clerk finishes entering the information on the Order Ticket, he or she must hit the "save" button, and the Order Ticket will be assigned a specific sequence number. Once the "save" button is hit, the Order Ticket cannot be modified and is stored by the Exchange as a JPEG file. Any ticket that is not saved within one minute will be discarded and the ticket number may be reused on a later ticket.
Order Tickets should not be created unless the broker or clerk has already received an order. A pattern or practice of creating Order Tickets that are subsequently discarded, which would be indicative that no order(s) had been received, could result in disciplinary action as appropriate.
After the Order Ticket is saved, a broker or clerk must enter the order information into BARS as soon as possible. In order for the Order Ticket enhancement to transfer both the Create Time and the sequence number from the Order Ticket into BARS, the Order Entry Template (or OET) must be launched directly from the saved Order Ticket JPEG.
It is also important to note that the BARS "Market Look" functionality should not be used to create an electronic order ticket and entry of order information in a "Market Look" template is not compliant with Amex rules.
For questions about rules and regulatory obligations, please contact David Fisch at 212-306-1450. For questions or additional information about BARS processing, please contact Corry Arnold at 212-306-1821 or Frank Vento at 212-306-1735.