Comparisons or Confirmations and "Don't Know Notices"
SERIES 7 | SERIES 24 | FINANCIAL REGULATION COURSES
FINRA Rule 11200 is the series-level marker for the second major subsection of the Uniform Practice Code — the organizational designation grouping the two substantive rules governing how member firms document and confirm the terms of their over-the-counter transactions with each other, and how a member proceeds when its counterparty fails to acknowledge a transaction at all. Its title — Comparisons or Confirmations and Don't Know Notices — identifies the subsection's two core concerns: the comparison or confirmation process through which both parties to a trade document and verify the terms of that trade against each other, and the Don't Know Notice procedure — discussed in detail in FINRA Rule 11210 and connected directly to FINRA Rule 11190's reconfirmation and pricing service provisions examined in this dictionary's immediately preceding entry — through which a member formally raises the question of whether its counterparty even recognizes the transaction at all.
FINRA Rule 11200 has no operative text. Its FINRA.org page returns no rule text under The Rule tab, shows no amendment history, and lists no selected notices — only the two child rules organized beneath it: FINRA Rule 11210, Sent by Each Party, and FINRA Rule 11220, Description of Securities.
FINRA Rule 11200 sits within the 11000 Uniform Practice Code as the second major subsection, positioned between FINRA Rule 11190 — the final rule of the 11100 Scope of Uniform Practice Code subsection — and FINRA Rule 11210, the first substantive rule of the 11200 subsection itself.
The Logical Position of the 11200 Subsection Within the Uniform Practice Code's Transaction Lifecycle
The 11200 subsection's position immediately following the 11100 subsection reflects a coherent progression through the lifecycle of a securities transaction under the Uniform Practice Code.
The 11100 subsection, examined in detail throughout this dictionary's preceding entries, established the foundational scope and non-cancellation principles of FINRA Rule 11100, the UPC Committee governance structure of FINRA Rules 11110 through 11112, the definitional framework of FINRA Rule 11120, the trade date provisions of FINRA Rules 11120(g) and 11121, the contingent-contract framework of FINRA Rule 11130 for when, as and if issued/distributed securities, and the various ex-date frameworks of FINRA Rules 11140 through 11170 — culminating in FINRA Rule 11190's provisions for resolving aged fails through reconfirmation and pricing services.
Having established this foundational and contingency framework, the Uniform Practice Code's 11200 subsection turns to the most basic documentary step in any ordinary transaction's lifecycle — the comparison or confirmation that each party sends to memorialize and verify the terms of the trade immediately after execution.
This is, in a sense, the Uniform Practice Code's return to first principles after the specialized contingencies addressed in the 11100 subsection's later provisions — every transaction, whether or not it involves the ex-date considerations of FINRA Rules 11140 through 11160, the part-redemption considerations of FINRA Rule 11170, or the contingent-contract considerations of FINRA Rule 11130, begins with the basic documentary step of comparison or confirmation that FINRA Rule 11210 governs.
The Relationship to FINRA Rule 11100(d)'s CUSIP Requirement
FINRA Rule 11200's subsection connects directly to a provision examined early in this dictionary's coverage of the Uniform Practice Code — FINRA Rule 11100(d)'s requirement that the CUSIP number be used on the Uniform Transfer Instruction Form, Uniform Delivery Ticket, and the Uniform Comparison or Confirmation. The Uniform Comparison or Confirmation referenced in FINRA Rule 11100(d) is the very document whose sending requirements FINRA Rule 11210 establishes within the FINRA Rule 11200 subsection. This connection illustrates how the Uniform Practice Code's foundational provisions in the 11100 subsection establish requirements — such as the mandatory CUSIP number — that are then operationalized through the specific documentary procedures of the 11200 subsection's rules.
The Relationship to FINRA Rule 11130(a)'s Standard Form Requirement
FINRA Rule 11200's subsection also connects to FINRA Rule 11130(a)(1)'s requirement that when, as and if issued/distributed transactions be confirmed using the Standard Forms set forth in FINRA Rule 11130's Supplementary Material .01, pursuant to the requirements of FINRA Rules 11210(a), 11220, and 11860. This cross-reference confirms that the general comparison and confirmation requirements FINRA Rule 11210 establishes within the FINRA Rule 11200 subsection — and the description-of-securities requirements FINRA Rule 11220 establishes — apply even to the specialized contingent contracts of FINRA Rule 11130, layered together with that rule's own Standard Form requirements rather than displaced by them. The FINRA Rule 11200 subsection's comparison and confirmation framework thus functions as a general-purpose documentary layer that applies across the various specialized transaction types the Uniform Practice Code addresses, including but not limited to the when, as and if issued/distributed contracts of FINRA Rule 11130.
"Don't Know Notices" as the Subsection's Distinctive Contribution
While the comparison or confirmation half of FINRA Rule 11200's title addresses what might be considered routine documentary practice — every transaction generates a comparison or confirmation as a matter of course — the Don't Know Notices half of the title addresses what happens when that routine practice breaks down. As the search results confirm regarding FINRA Rule 11210's structure, when a party to a transaction sends a comparison or confirmation of a trade but does not receive a comparison or confirmation or a signed DK from the contra-member by the end of the day on the trade date, a specific Don't Know Notice procedure becomes available — involving a prescribed FINRA form, specific service methods including certified mail with return receipt requested or messenger delivery, and a defined response timeline giving the contra-member one business day after receipt to either confirm or DK the transaction.
This Don't Know Notice procedure is the documentary precursor to — and a key input for — the reconfirmation and pricing service framework of FINRA Rule 11190 examined in this dictionary's immediately preceding entry. A transaction that generates a DK under the FINRA Rule 11210 Don't Know Notice procedure, and that subsequently ages without resolution, is precisely the kind of transaction that FINRA Rule 11190(a)'s mandatory reconfirmation and pricing service participation requirement is designed to address — and FINRA Rule 11190(b)(1)'s DK-based close-out authorization operates on contracts that have been DK'd, whether that DK designation originated through the FINRA Rule 11210 Don't Know Notice procedure at the trade-date level or through the reconfirmation and pricing service's own DK determination at the aged-fail level.
The Confirmed Carve-Out for Clearing-Agency-Processed Transactions
A significant structural feature confirmed from the FINRA Rule 11210 search results is that this Rule shall not be applicable to transactions which clear through the National Securities Clearing Corporation or other clearing organizations registered under the Exchange Act. This carve-out within FINRA Rule 11210 mirrors, at the 11200 subsection level, the broader carve-out FINRA Rule 11100(a)(1) establishes at the level of the entire Uniform Practice Code — transactions compared, cleared, or settled through a registered clearing agency are generally excluded from Uniform Practice Code coverage, except to the extent the clearing agency's own rules provide that other organizations' rules apply.
This carve-out confirms, once again, the characterization of the Uniform Practice Code established in this dictionary's entry on FINRA Rule 11000 — the Uniform Practice Code, including its FINRA Rule 11200 subsection's comparison, confirmation, and Don't Know Notice procedures, functions as a backstop framework for the diminishing — but not eliminated — category of transactions that fall outside the highly automated processing of registered clearing agencies such as NSCC. For the overwhelming majority of equity transactions that clear through NSCC's continuous net settlement system, NSCC's own comparison, confirmation, and exception-handling procedures govern rather than FINRA Rule 11210's comparison, confirmation, and Don't Know Notice procedures — but for the transactions that fall outside that NSCC processing, FINRA Rule 11210's procedures remain the operative framework.
Connection to FINRA Rules 11100, 11130, 11190, 11210, and 11220
FINRA Rule 11200 connects to FINRA Rule 11100(a)(1) and (d) — the clearing-agency carve-out principle that FINRA Rule 11210 mirrors at the subsection level, and the CUSIP number requirement for the Uniform Comparison or Confirmation that FINRA Rule 11210 operationalizes. It connects to FINRA Rule 11130(a)(1) — whose Standard Form requirements for when, as and if issued/distributed contracts operate alongside, rather than instead of, the general FINRA Rule 11210 and FINRA Rule 11220 requirements that FINRA Rule 11130(a)(1) expressly cross-references. It connects to FINRA Rule 11190 — whose reconfirmation and pricing service framework for aged fails represents the next stage in the documentary lifecycle for transactions that generate a DK under the FINRA Rule 11210 Don't Know Notice procedure and subsequently remain unresolved. And it connects directly to its own two child rules — FINRA Rule 11210, which this dictionary will examine next and which establishes the comparison or confirmation sending requirements and the Don't Know Notice procedure itself, and FINRA Rule 11220, which establishes the description-of-securities content requirements for those comparisons and confirmations.
Examination Relevance and Key Takeaways
FINRA Rule 11200 is tested on the Series 7 and Series 24 examinations as the series-level marker for the Uniform Practice Code's comparison, confirmation, and Don't Know Notice framework — the documentary layer governing the most basic step in any over-the-counter transaction's lifecycle.
The key points to retain are these: FINRA Rule 11200 is the series-level marker for a two-rule subsection — FINRA Rule 11210, Sent by Each Party, and FINRA Rule 11220, Description of Securities — with no operative text, no amendment history, and no selected notices of its own; the subsection addresses two related concerns — the routine comparison or confirmation that each party to a transaction sends to document and verify the trade's terms, and the Don't Know Notice procedure available when a party fails to receive a comparison, confirmation, or signed DK from its counterparty by the end of the trade date; the Don't Know Notice procedure connects directly to FINRA Rule 11190's reconfirmation and pricing service framework, since a transaction that generates a DK and subsequently ages without resolution is precisely the category of transaction FINRA Rule 11190 addresses; the FINRA Rule 11200 subsection's comparison and confirmation framework operationalizes FINRA Rule 11100(d)'s mandatory CUSIP number requirement for the Uniform Comparison or Confirmation, and operates alongside — rather than being displaced by — FINRA Rule 11130(a)(1)'s Standard Form requirements for when, as and if issued/distributed contracts; and FINRA Rule 11210 itself confirms a carve-out excluding transactions that clear through NSCC or other registered clearing agencies from its coverage, mirroring the broader FINRA Rule 11100(a)(1) clearing-agency carve-out at the level of the entire Uniform Practice Code.
