Key Takeaways
- QSRs enable direct trade submission to NSCC.
- Bypasses Nasdaq ACT for faster settlement.
- Allows extended trading hours and ECN support.
- Exclusive to NSCC full-service members.
What is Qualified Special Representative Agreement (QSR)?
A Qualified Special Representative Agreement (QSR) is a contractual arrangement between broker-dealers or members of the National Securities Clearing Corporation (NSCC) that allows one party to submit and settle trades directly on behalf of another, bypassing the Nasdaq Automated Confirmation Transaction (ACT) system for greater efficiency. This specialized agreement streamlines trade processing in U.S. securities markets by enabling faster and more cost-effective settlement.
QSRs are distinct from tax withholding agreements and are primarily designed to facilitate trade clearing, improving the operational workflow of high-volume broker-dealers and market participants.
Key Characteristics
QSRs offer specific features that enhance trade submission and settlement processes:
- Direct Clearing Submission: Enables trades to be sent directly to the NSCC, avoiding Nasdaq ACT delays.
- Extended Trading Hours: Supports trade settlement outside regular market hours, including pre-market and after-hours.
- Qualified Members: Only NSCC full-service members with QSR status can enter these agreements.
- Efficient Trade Lock-In: Facilitates locking in trades swiftly between counterparties, reducing settlement risk.
- Integration with ECNs: Works seamlessly with electronic communication networks that match orders internally before clearing.
- Scope of Application: Typically applies to NMS stocks and OTC equity securities under NSCC rules.
How It Works
Under a QSR, a broker-dealer authorized as a Qualified Special Representative directly submits trade details to the NSCC on behalf of another member. This bypasses the Nasdaq ACT system, accelerating the clearing process and lowering operational costs.
For example, when two broker-dealers internally match trades via an electronic communication network, the QSR submits the transaction directly to their clearing firm. The clearing firms then handle settlement at the NSCC, ensuring both parties’ trades are confirmed and locked in without the typical ACT reporting step.
Examples and Use Cases
QSR agreements are commonly used by large broker-dealers and market participants seeking to optimize trade settlement efficiency. Typical examples include:
- Airlines: Delta and American Airlines utilize advanced trading and clearing mechanisms, including QSRs, to manage corporate securities and employee stock plans efficiently.
- Broker-Dealers: Firms leveraging best online brokers often engage in QSR agreements to expedite trade processing and reduce settlement risks.
- Investment Managers: Those investing in growth stocks may benefit indirectly from market liquidity improvements attributed to QSR-enabled trade workflows.
Important Considerations
While QSR agreements provide operational advantages, they require careful adherence to NSCC rules and eligibility requirements. Only qualified members can act as representatives, and the agreement must clearly define the scope of trade submission authority.
Additionally, QSRs do not replace broader trade reporting obligations, such as those to FINRA’s Trade Reporting Facility, and are limited to clearing submission processes. Understanding the distinction between QSR trade clearing and market reporting is essential for compliance and operational efficiency.
Final Words
A Qualified Special Representative Agreement streamlines trade settlement by letting approved members bypass Nasdaq’s ACT system for faster, cost-effective processing. To optimize your trade operations, evaluate whether partnering with a QSR member aligns with your trading volume and settlement needs.
Frequently Asked Questions
A Qualified Special Representative Agreement (QSR) is an arrangement between broker-dealers or NSCC members that allows one party to submit and settle trades directly to a clearinghouse on behalf of another, bypassing the Nasdaq ACT system for faster and more efficient trade processing.
QSRs enable faster, simpler, and more cost-effective trade execution by allowing trades to be submitted directly to the National Securities Clearing Corporation (NSCC) instead of routing through Nasdaq's ACT system, which can be slower and limited to regular trading hours.
Qualified Special Representatives are typically NSCC full-service members such as broker-dealers, custodians, or clearing participants who meet NSCC eligibility requirements and enter into bilateral QSR agreements with counterparties.
QSRs are used to submit trades directly to the NSCC for eligible transactions like NMS stocks or OTC equity securities, especially when trades occur outside regular market hours or involve electronic communication networks (ECNs) that internally match orders.
No, a QSR only governs the submission and settlement of trades through the NSCC and does not change any broader trade reporting obligations, which remain subject to rules from FINRA and other regulatory bodies.
The main benefits include faster trade settlement, the ability to trade during extended hours, reduced costs, and streamlined processing by bypassing the Nasdaq ACT system, which enhances liquidity and operational efficiency for high-volume broker-dealers.
In practice, one broker acting as a QSR submits trade details directly to its clearing firm on behalf of another broker, allowing both parties to lock in trades at the NSCC without the trades first passing through Nasdaq's ACT system, making settlement quicker and more efficient.

