Starting in Phases 2a (equities) and 2b (options), orders received or originated prior to the date on which an Industry Member is required to begin reporting to the CAT and any subsequent events related to such orders, including those occurring on or after the required reporting date, are not required to be reported to the CAT. However, Industry Members may submit to the CAT events related to orders received or originated prior to the required reporting date and they will not be rejected.
For Phase 2a/2b reporting, if an Industry member chooses to optionally report subsequent events related to such orders, the orderKeyDate field must be populated with a date prior to the date on which the Industry Member is required to begin reporting to CAT, and the Industry Member will receive a warning that the Order Key references a date prior to CAT go-live. If the Industry Member populates the orderKeyDate field with a date on or after the date on which the Industry Member is required to begin reporting to CAT, the Industry Member will receive an error that the Order Key is not found.
For Phase 2a/2b reporting, if the sending firm chooses not to report the activity, but the receiving firm reports an MEOA to CAT, both parties will receive a linkage error as the CAT Plan Processor would have no way to distinguish that the original order was received by the receiving firm prior to CAT go-live. In this case, both parties that received an error should contact the FINRA CAT Help Desk. Industry Members should note that this issue will only impact CAT Reportable Events for orders received prior to the start of CAT reporting (June 22, 2020 for equities and July 20, 2020 for simple electronic options), which are routed on or after the date when interfirm linkage processing becomes effective (July 27, 2020 in Industry Test Environment and August 10, 2020 in the Production Environment).
Starting in Phase 2c, for orders that originated/generated prior to April 26, 2021 and that remain open on April 26, 2021, Industry Members would be required to report any subsequent events in accordance with applicable Phase 2c reporting requirements. For example, if a trailing stop order received on March 3, 2021 remains open on April 26, 2021, then the Industry Member would be required to report an Order Effective event when all underlying conditions are met (e.g., the trailing stop is triggered) in accordance with Phase 2c requirements instead of via an Order Modified event (MEOM), as was required in Phase 2a. (See FAQ B62 for information related to the reporting requirements for Trailing Stop and Trailing Stop Limit orders.)
Starting in Phase 2d, for orders that originated/generated prior to December 13, 2021 and that remain open on December 13, 2021, Industry Members would be required to report any subsequent events in accordance with applicable Phase 2d reporting requirements. For example, on December 14, 2021, a customer requests a modification or cancellation to a GTC order that was originally generated on October 5, 2021. In this example, the Industry Member must also capture the time that the cancellation or modification request was received from the customer either in the requestTimestamp field in the Order Modified event (MEOM) or Order Cancelled event (MEOC), as applicable, or in separate Order Modification Request event (MEOMR) or Order Cancel Request event (MEOCR), as outlined in the Reporting Technical Specifications for Industry Members document.
For orders that remain open on or after December 13, 2021, and that were not required to be reported prior to Phase 2d, then the subsequent events associated with such orders are not required to be reported if the primary event(s) associated with such activity was not reportable prior to Phase 2d. The Industry Member may choose to optionally report such secondary events to the CAT, but must populate the orderKeyDate field with a date prior to December 13, 2021, and the Industry Member will receive a warning that the Order Key references a date prior to CAT go-live. If the Industry Member populates the orderKeyDate field with a date on or after December 13, 2021, then the Industry Member will receive an error that the Order Key is not found.
For example, a Multi-Leg Order was generated on December 9, 2021and was not required to be reported to CAT prior to Phase 2d. The order remains open on December 14, 2021, when the Industry Member routes the Multileg Order to an exchange. The route is not required to be reported, as it relates to an order that was originated/generated and not reportable prior to Phase 2d. The Industry Member may optionally choose to report the route to an exchange via the Multi-Leg Order Route event (MLOR), but must populate the orderKeyDate field with December 9, 2021, the Order Key of the primary event which is being routed. The same guidance would apply to any other subsequent events on the multi-leg order.