A firm performs multiple functions on the same desk or within the same department, such as program trading and non-program trading. Is an Internal Route Event required for orders sent between traders that perform those separate functions?
If separate and distinct functions are performed within the same desk or department of a firm, an Internal Route Event may be required if an order is passed between traders who perform different functions. For example, an order would be considered to have been transferred to another department for CAT reporting purposes, if it were transferred between functions that the firm considers to be independent aggregation units for purposes of SEC Regulation SHO (See SEC Rule 200(f)).