Quotes entered directly into the OTC Link IDQS via OTC Link IDQS’s Dealer Application are captured in a structured electronic format. Pursuant to the SEC’s June 16, 2025 order “unstructured electronic and verbal communications that are not currently captured by Industry Member order management of execution systems” (e.g., electronic chats, text messages) are not reportable to CAT. 

As quotes entered directly in the OTC Link IDQS via OTC Link IDQS’s Dealer Application are structured, they are not covered by the SEC’s Order and are reportable beginning in Phase 2d. Because these quotes are entered manually into the Dealer Application, they are considered to be manually originated and manually routed. As such, the Industry Member entering a quote directly into the OTC Link IDQS via the Dealer Application would report a New Quote event with the manualFlag set to ‘true’ and a Routed Quote event with the manualFlag set to ‘true’. The OTC Link IDQS would report a Quote Received event with the manualFlag set to ‘true’.