Series 24 Exam · 14 min read 2026 Blueprint Verified

Market Making, Reg NMS, Order Handling & TRACE Reporting Deadlines on Series 24

Rob Pfleghardt

10-year Price Waterhouse alumnus · Founder of VoraPrep · Former CPA (1987–2024) · with the VoraPrep Editorial Team

Market Making, Reg NMS, Order Handling & TRACE Reporting Deadlines on Series 24

Key Takeaways

  • Reg NMS is not a suggestion; it is a critical set of rules designed to ensure fair and efficient price discovery across all U.S. equity markets.
  • Best execution obligations extend beyond just price, encompassing speed, likelihood of execution, and order size, demanding sophisticated supervisory oversight.
  • Market maker responsibilities involve firm quotes and continuous pricing, with specific rules governing withdrawal to prevent market disruption.
  • TRACE reporting is time-sensitive, requiring real-time submissions for corporate and agency bonds, and principals must implement robust systems to ensure compliance.
  • The Series 24 exam often tests your ability to apply these complex rules to real-world scenarios, identifying situations that trigger specific regulatory requirements.
  • Supervisors must understand the "spirit" of the rules, not just the "letter," to identify potential conflicts of interest or manipulative practices.

Understanding the intricacies of market making, Reg NMS, order handling, and TRACE reporting on the Series 24 exam isn't just about memorizing rules; it's like preparing for a high-stakes legal proceeding where the precise interpretation of statutory language and case precedent determines the outcome. A single misjudgment, a failure to connect a specific trading scenario to the underlying regulatory intent, can lead to costly compliance failures and exam points hemorrhaged.

Quick answer

Series 24 principals must ensure their firm's compliance with Reg NMS (Order Protection, Access, Sub-Penny, Market Data Rules), uphold best execution and fair order handling practices, supervise market-making obligations, and meet strict TRACE reporting deadlines for corporate and agency debt securities to maintain market integrity and avoid FINRA violations.

Key facts

Exam Sections
150 scored questions across 5 supervisory functions.
Official Body
Financial Industry Regulatory Authority (FINRA).
Passing Score
A score of 70% or higher is required to pass the Series 24 exam.
Study Hours
Candidates typically dedicate 80-120 hours of focused study time.
Average Salary
The U.S. Bureau of Labor Statistics reported a median annual salary of $90,000 to $180,000 for securities, commodities, and financial services sales agents, a role often overseen by a Series 24 principal, as of May 2023 (BLS).
Exam Format
Multiple-choice questions, administered at Prometric test centers.

Mastering Complex Regulatory Areas: A 7-Day Sprint for Series 24

The Series 24 exam demands more than surface-level knowledge; it requires you to internalize the why behind the rules. These aren't just arbitrary regulations; they are cornerstones of market integrity. You cannot afford to treat Reg NMS, order handling, market making, or TRACE reporting as isolated topics. They are interconnected, forming the backbone of fair and orderly markets. Our approach at VoraPrep is to teach you to think like the examiner, spotting the nuance and the traps.

Ready to sharpen your focus? Here’s a 7-day sprint designed to solidify your understanding of these critical Series 24 topics for the 2026 exam.

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Day 1: Laying the Foundation for Reg NMS

Your first step is to establish a rock-solid understanding of Regulation NMS (National Market System), which governs the trading and quoting of NMS stocks. This regulation fundamentally reshaped U.S. equity markets to ensure fair pricing and access.

Reg NMS consists of four core rules: the Order Protection Rule, the Access Rule, the Sub-Penny Rule, and the Market Data Rule. As a principal, you are responsible for ensuring your firm's compliance with each of these. The common trap here is to confuse the purpose of each rule with its specific mechanics. For instance, many candidates mistakenly think the Order Protection Rule is solely about sending an order to the best price, overlooking its emphasis on avoiding trade-throughs.

Let's break them down:

  • Order Protection Rule (Rule 611): This rule prevents "trade-throughs" in NMS stocks. A trade-through occurs when an order is executed at an inferior price to a protected bid or offer displayed by another market center. It mandates that market participants establish, maintain, and enforce policies and procedures reasonably designed to prevent trade-throughs. The critical element is "protected bid" or "protected offer," meaning the best displayed price from an automated trading center.
  • Access Rule (Rule 610): This rule ensures fair and non-discriminatory access to quotations. It prohibits market centers from imposing unfair fees or conditions on access to their quotes. It also sets a maximum access fee of $0.003 per share. A common misconception is that this rule forces all market centers to accept all orders; rather, it focuses on equitable access once a quote is displayed.
  • Sub-Penny Rule (Rule 612): This rule prohibits the display of quotations, or the acceptance of orders, in NMS stocks priced at $1.00 or more in increments smaller than $0.01. For stocks priced under $1.00, the minimum increment is $0.0001. This prevents fragmentation and improves price transparency.
  • Market Data Rule (Rules 601 and 603): These rules ensure that market data (quotes and trades) is widely disseminated and reasonably priced. They govern the collection and distribution of consolidated market data, ensuring all participants have access to the same information at the same time.
Try VoraPrep's free Series practice questions to test your understanding of these foundational rules.

Day 2: Order Handling and Best Execution

Your next task is to deeply understand the principal's role in ensuring proper order handling and achieving best execution for customer orders. This goes beyond simply finding the lowest price.

Best execution means a broker-dealer must use reasonable diligence to ascertain the best market for a security and buy or sell in that market so that the customer's total cost or proceeds are as favorable as possible under prevailing market conditions. This is not a guarantee of the absolute best price, but an obligation to employ diligence to achieve the most advantageous terms for the customer.

Factors considered for best execution include:

  • Price: The most obvious factor, but not the only one.
  • Speed and certainty of execution: How quickly and reliably the order can be filled.
  • Size of the order: The ability to execute a large order without undue market impact.
  • Trading characteristics of the security: Liquidity, volatility, and typical trading patterns.
  • Accessibility of the quotation: How easy it is to reach the displayed price.

A common exam trap involves scenarios where a principal routes an order to an affiliated market maker without considering external markets. While permitted, this practice carries a heightened best execution obligation, requiring the principal to demonstrate that the affiliated venue provided terms as good as or better than available external markets. Simply routing to an affiliate for convenience is a violation.

Exam trap: Your firm receives a large customer order for an NMS stock. Your firm's affiliated market maker has a quote that is slightly worse than the National Best Bid/Offer (NBBO) but offers faster execution. The principal directs the order to the affiliate. Is this a violation? Tempting wrong answer: No, because speed of execution is a factor in best execution. Correct approach: Yes, this is likely a violation. While speed is a factor, the principal's primary obligation is to achieve the most favorable terms. Routing to an inferior price just for speed, especially when a better price is readily available, often fails the best execution standard. The principal must justify that the total value (price + speed + other factors) was superior, not just one factor in isolation. The Order Protection Rule (Reg NMS Rule 611) would also likely be violated if the order trades through a better-priced protected quote.

Day 3: Market Making Obligations and Rules

Today, you'll focus on the specific duties and regulatory framework surrounding market making. A market maker provides liquidity to the market by continuously quoting both a bid (price they'll buy at) and an offer (price they'll sell at) for a given security.

Key responsibilities of a FINRA market maker include:

  • Firm Quotes: Under FINRA Rule 5210 (Publication of Transactions and Quotations), market makers must honor their displayed quotations. If a market maker displays a quote for 100 shares at $20.00 bid / $20.05 offer, they must be willing to trade at least 100 shares at those prices.
  • Continuous Quoting: Market makers are expected to maintain continuous, two-sided quotes during trading hours. This ensures liquidity.
  • Passive vs. Active Market Making: While not explicitly tested as "passive" or "active," understanding the difference is crucial. Passive market making attempts to match customer orders with existing quotes without significantly impacting the market. Active market making involves taking on inventory risk and actively seeking to profit from the spread.
  • Withdrawal of Quotations (FINRA Rule 6240): A market maker cannot simply withdraw their quotes at will. FINRA Rule 6240 requires a market maker to notify FINRA of its withdrawal from a security and generally prohibits re-entry into that security for one business day. This prevents market disruption and ensures stability. Exceptions exist, such as for legitimate business reasons (e.g., system failure, regulatory halt).
Comparison of Market Maker Actions

Day 4: TRACE Reporting Deadlines and Rules

Today is about understanding TRACE (Trade Reporting and Compliance Engine), FINRA's system for the reporting of over-the-counter (OTC) secondary market transactions in eligible fixed income securities. As a principal, ensuring accurate and timely reporting is a non-negotiable compliance function.

TRACE applies to most corporate bonds, agency bonds (both government-sponsored enterprise (GSE) debt and federal agency debt), and certain mortgage-backed securities (MBS). It does NOT apply to U.S. Treasury securities or municipal securities (which are reported through EMMA).

The primary goal of TRACE is to increase transparency in the historically opaque OTC bond market. This transparency benefits both investors and regulators.

Key reporting deadlines:
  • Real-time Reporting (Rule 6730): Most corporate and agency bond transactions must be reported to TRACE as soon as practicable, but no later than 15 minutes after the time of execution. This is the critical deadline you'll be tested on repeatedly.
  • End-of-Day Reporting: Transactions executed on a non-business day or outside of TRACE system hours (e.g., after 6:30 p.m. ET) must be reported by 6:30 p.m. ET on the next business day.
  • Late Reporting: Any transaction reported after the 15-minute window is considered late and must be explicitly marked as such. Frequent late reporting can lead to significant fines and regulatory scrutiny.
Worked example: TRACE Reporting Scenario

A registered representative at your firm executes a customer purchase of $500,000 face value of XYZ Corp. 5% bonds at 10:10 a.m. ET on a Tuesday. The trade is confirmed and allocated by 10:12 a.m. ET.

Task: Determine the latest time this transaction must be reported to TRACE. Step 1: Identify the security type. XYZ Corp. bonds are corporate bonds, which are eligible for TRACE reporting. Step 2: Identify the execution time. The trade was executed at 10:10 a.m. ET. Step 3: Apply the standard reporting deadline. For corporate bonds, the rule is "as soon as practicable, but no later than 15 minutes after execution." Step 4: Calculate the deadline. 10:10 a.m. ET + 15 minutes = 10:25 a.m. ET. Answer: The transaction must be reported to TRACE by 10:25 a.m. ET. If reported at 10:26 a.m. ET, it would be considered a late report, even if it's only one minute past the deadline.

As a principal, you are responsible for supervising the systems and personnel to ensure these deadlines are consistently met.

For a deeper dive into all critical deadlines, consult our Series 24 Cheat Sheet (2026): Filing Deadlines, Retention Periods & FINRA Rules.

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Day 5: Supervisory Responsibilities and Compliance

Now, it's time to integrate your knowledge by focusing on the principal's overarching supervisory responsibilities across all these areas. Your primary role is to establish, maintain, and enforce written supervisory procedures (WSPs) designed to achieve compliance.

FINRA Rule 3110 (Supervision) is your guiding star. It mandates that each firm must designate one or more principals to supervise the activities of its registered representatives and associated persons. This includes:

  • Reviewing and Approving: All new accounts, customer orders, and correspondence.
  • Training: Ensuring all personnel are adequately trained on firm policies and regulatory requirements related to Reg NMS, order handling, market making, and TRACE.
  • Monitoring and Surveillance: Implementing systems to detect potential violations, such as trade-throughs, failure to achieve best execution, market manipulation, or late TRACE reports.
  • Recordkeeping: Maintaining accurate and accessible records of all transactions, supervisory reviews, and compliance efforts.
Tip: When faced with a Series 24 question about supervisory responsibility, always ask yourself: "What written procedures should be in place to prevent this issue, and what actions should the principal take to enforce them?" The answer often involves WSPs, training, and surveillance.

Consider a scenario where your firm uses an algorithmic trading system. As a principal, you must ensure that the algorithm is programmed to comply with Reg NMS, that it has internal controls to prevent errors, and that its performance is regularly reviewed for best execution. It's not enough to trust the technology; you must supervise its output and compliance.

Day 6: Practice Application and Weak Area Targeting

Today is for putting it all together. You need to identify your weak spots and drill them relentlessly. VoraPrep's adaptive learning engine excels here, targeting the subtopics where you need the most work.

Focus on scenario-based questions that integrate multiple concepts. For example:

  • A question might describe a market maker's actions that lead to a trade-through, requiring you to identify both the Reg NMS violation and the market maker's specific rule infraction.
  • Another might present a complex bond trade and ask about the TRACE reporting deadline, then follow up with a question about the principal's supervisory duty if the report is late.

Use our extensive Series 24 practice questions to simulate exam conditions. Pay close attention to the detailed explanations, especially for questions you answer incorrectly. Understand why the right answer is right, and why the tempting wrong answers are wrong. This is how you develop the "examiner's mindset."

You can also leverage Vory, your 24/7 personal tutor, to help you break down complex questions or clarify specific rules within the practice bank. Vory can provide step-by-step coaching on how to approach these multi-faceted problems.

Day 7: Comprehensive Review and Final Check

Your final day in this sprint is for a comprehensive review of all the topics covered. Revisit your notes, re-read the most challenging rules, and take a full-length practice exam.

Here's a checklist for your final review:

  • Reg NMS Rules: Can you articulate the purpose and key provisions of Rules 610, 611, 612, 601, and 603 without hesitation?
  • Best Execution Factors: Can you list the key factors for best execution beyond just price, and explain how a principal ensures compliance?
  • Market Maker Obligations: Do you understand firm quotes, continuous quoting, and the rules for withdrawing quotations?
  • TRACE Reporting: Are you clear on which securities are reported, the 15-minute deadline, and the exceptions for non-business hours?
  • Supervisory Procedures: Can you describe the WSPs a principal needs to establish for each of these areas under FINRA Rule 3110?

This intensive 7-day sprint provides a structured path to mastery. Remember, the Series 24 exam isn't about rote memorization; it's about applying complex regulatory knowledge to protect investors and maintain market integrity.


⚡ Test Yourself: 1 Real SERIES24 Question · Instant Reveal
Series 24 Section 2: Supervision of General Broker-Dealer Activities

Under FINRA Rule 3110 (Supervision) and Rule 2210 (Communications with the Public), when must a General Securities Principal approve a retail communication that does not make a financial or investment recommendation?

Frequently asked questions

What is Reg NMS and why is it important for the Series 24 exam?

Regulation NMS (National Market System) is a set of SEC rules designed to improve the fairness and efficiency of U.S. equity markets. For the Series 24 exam, understanding Reg NMS is crucial because principals are responsible for ensuring their firm's compliance with its core tenets: preventing trade-throughs (Order Protection Rule), ensuring fair access to quotes (Access Rule), maintaining minimum price increments (Sub-Penny Rule), and facilitating market data dissemination (Market Data Rule).

What are the TRACE reporting requirements for the Series 24 exam?

TRACE (Trade Reporting and Compliance Engine) requires broker-dealers to report secondary market transactions in eligible corporate, agency, and certain mortgage-backed securities to FINRA. The most critical requirement for the Series 24 exam is the "real-time" reporting rule, which mandates transactions be reported as soon as practicable, but no later than 15 minutes after execution. Principals must supervise systems and procedures to ensure timely and accurate reporting.

How does "best execution" relate to a Series 24 principal's duties?

Best execution is a fundamental obligation requiring broker-dealers to use reasonable diligence to ascertain the best market for a security and execute customer orders to achieve the most favorable terms possible. A Series 24 principal must establish and enforce WSPs to ensure best execution, considering factors beyond just price, such as speed, certainty of execution, and order size. This often involves regular review of execution quality and order routing practices.

What are the key market making obligations tested on the Series 24 exam?

Series 24 candidates should know that market makers have obligations to provide liquidity by continuously quoting firm bids and offers for securities. Key rules include FINRA Rule 5210, which requires market makers to honor their displayed quotes, and FINRA Rule 6240, which governs the procedures for withdrawing quotations and prohibits re-entry for one business day without exception. Principals supervise these activities to ensure market integrity.

Official resources and references


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About the Author: Rob Pfleghardt

Rob Pfleghardt is the founder of VoraPrep, a comprehensive exam prep platform across 30 professional licensure and certification exams in Accounting & Tax (CPA, EA, CMA, CFE, CPP, CGFM), Securities & Wealth (CFP, SIE, FINRA Series, CFA, FRM), Audit & Cyber (CISA, CIA, CRISC, CISM, CISSP, CCSP, Security+, CIPP/US), HR Leadership (SHRM-CP, PHR), and Federal Regulatory (CBLE). A Virginia Tech graduate in Accounting and Finance, Rob began his career at Price Waterhouse, spending a decade in audit and IT consulting. After holding a CPA license for 37 years (1987–2024) and scaling his own enterprise IT consultancy serving commercial and federal clients, Rob launched VoraPrep to build adaptive training technology and blueprint-aligned curriculum for working professionals.

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