Archived FAQs

Currently, the Participants are funding the CAT-related costs themselves. The CAT NMS Plan, however, contemplates a funding model in which both Participants and Industry Members contribute to the funding of the CAT. Although the Participants have filed fee filings with the SEC to impose CAT Fees on Participants and Industry Members, the Participants have withdrawn these fee filings at this time. The Participants anticipate filing revised fee filings in the near future.

This FAQ was retired on October 12, 2023.

While SEC Rule 613(a)(3) and Section 6.7(a) of the CAT NMS Plan require that Participants begin reporting to the CAT by November 15, 2017, Industry Members (other than Small Industry Members) begin reporting to the CAT by November 15, 2018, and Small Industry Members begin reporting to the CAT by November 15, 2019, the CAT System currently is not ready to accept data from Industry Members. Although the SEC has not granted an extension to these dates the Operating Committee anticipates that Large Industry Members and Small Industry Members currently reporting to OATS will begin reporting to the CAT in April 2020 and Small Industry Members that are not currently reporting to OATS will begin reporting in December 2021.

This FAQ was retired on May 21, 2020.

If a Reportable Event is priced in a non-U.S. dollar currency, CAT Reporters are required to convert such prices into U.S. dollars based on the conversion rate applicable at the time that the Reportable Event occurred and report the prices in US dollars to the CAT. Although a specific conversion methodology is not prescribed, any methodology must be applied consistently by the Industry Member. The treatment of prices in non-U.S. dollar currencies is consistent with FINRA’s treatment of such prices under OATS reporting requirements (See Compliance FAQ C71 available at: http://www.finra.org/industry/faq-oats-compliance-faq).

This FAQ was retired on September 23, 2020.

For Phase 2c, “if available in the booking system” means that the FDID is either directly available in the booking system, or can be made available through a simple reference data lookup, or can be readily accessed by the booking system through an existing system integration. For example, if the FDID is directly stored or can be directly queried by the booking system, the newOrderFDID field should be populated. In contrast, if, in order to supply the FDID, a new system integration would be required or if new data element(s) were required in the booking record, then the newOrderFDID field would not be required to be populated. It should also be noted that requirements for populating this field may be expanded in future phases of CAT.

This FAQ was retired on July 17, 2020.

No.  As noted in FAQ K4, options assignments and exercises are not orders, as defined by SEC Rule 613, and therefore are not required to be reported to CAT.  Therefore, Industry Members are also not required to report the resulting booking of shares into a customer account resulting from an options assignment or exercise.  Similarly, Industry Members are not required to report the booking of shares or contracts into a customer account resulting from other non-CAT Reportable events (e.g., conversions of a convertible bond into an equity).  As noted in the Industry Member Technical Reporting Specifications, Industry Members may voluntarily report clearing events to CAT that are not required as long as they are properly identified as set forth in the Industry Member Technical Reporting Specifications.

This FAQ was retired on March 9, 2021.

OATS reporting obligations are separate and distinct from CAT reporting obligations, and a firm’s CAT reporting obligation may be different from its OATS reporting obligation. If a firm’s system captures timestamps in nanoseconds, then its CAT events must be reported to nanosecond granularity, even though its OATS submission will only reflect millisecond granularity since OATS does not accept nanoseconds.

This FAQ was retired on November 12, 2021.

In this scenario, Industry Members must populate the orderType as ‘LMT’ and the price as “0”. Refer to FAQ E9 for instructions on orders routed with handlingInstructions that include pricing criteria.

This FAQ was retired on July 1, 2020.

Routes not accepted by the receiving market participant will be required to be reported to CAT beginning in Phase 2c. These routes must be reported with a flag indicating they were not accepted by the receiving market center.

This FAQ was retired on August 27, 2020.

The Order Route Event for orders routed as Stop orders should include an OrderType of either market or limit and a handling instruction of STOP or other appropriate handling instruction as applicable. 

This FAQ was retired on July 1, 2020.

If an order is received/originated or routed without a specific limit price but includes handlingInstructions that may include certain pricing criteria, such as a ‘PEG’ or options related order, the orderType field may be populated as either ‘MKT’, or ‘LMT’ with a price of ‘0’. The ‘PEG’ or other instruction must be included in the handlingInstructions field on the event. If an order is not a market order but is received or originated without a specific limit price and does not have handlingInstructions that include pricing criteria, such as an order that is originated to represent multiple customer orders but does not have a set limit price, the orderType field must be populated as ‘LMT’ and the price must be ‘0’.

This guidance does not apply to Stop or Stop Limit orders - refer to FAQ B57 for additional information on the orderType field for Stop, Stop Limit, Stop on Quote, Stop Limit on Quote, Trailing Stop, and Trailing Stop Limit orders.

This FAQ was retired on July 1, 2020.

Members that have either facilitated a basket trade or crossed two customers’ baskets and submitted the information to NYSE’s Crossing Session II, should report these transactions to CAT as a Trade Event. The event timestamp reported to CAT should be the time the member crossed or facilitated the basket and not the acknowledgment time received back from NYSE. Further, the Trade event must contain the marketCenterID of “N” to designate the New York Stock Exchange and the tapeTradeID should be populated with “NYSE CS2” to denote the transaction was reported to the Crossing Session II.

This FAQ was retired on July 3, 2024.

No. Unless a new account or entity identifier is assigned to a client or customer, each Firm Designated ID (FDID) must be unique, persistent and consistent for each trading account within the firm and across all vendors and systems the Industry Member may use to report Transaction Order events requiring an FDID to CAT and associated Customer and Account information for the FDID to CAT CAIS, and unique across time (with limited exceptions as noted in FAQ M16).

This FAQ was retired on May, 5, 2026.

Before the reporting of Customer Account Information and Customer Identifying Information begins with the implementation of Phase 2e (Full CAIS), regulatory users of the CAT will use FDIDs to identify whether the same account is trading within a single broker-dealer. After the reporting of Customer Account Information and Customer Identifying Information begins, FDIDs will be used to link accounts to specific Customers, including mapping accounts with common ownership (for instance, where a Customer is associated with more than one FDID).

This FAQ was retired on May 5, 2026. 

Industry Members (other than Small Industry Members) and Small Industry Members that are required to record and report information to FINRA’s Order Audit Trail System pursuant to applicable SRO rules (“Small Industry OATS Reporters”) must commence reporting Firm Designated IDs (FDID) on all Transaction Order events requiring an FDID to the CAT in Phase 2a beginning on June 22, 2020. Small Industry Members that are not Small Industry OATS Reporters must commence reporting FDIDs on all Transaction Order events requiring an FDID to the CAT by December 13, 2021.

This FAQ was retired on May 5, 2026.

No. Each Industry Member must make its own determination whether it believes it is necessary to mask the actual account number for any proprietary account of the firm when reporting the FDID to CAT.

This FAQ was retired on May 5, 2026.

No. The Plan Participants are not prescribing any specific methodology that must be used to mask or otherwise transform account numbers for the purposes of reporting the Firm Designated ID (FDID) to CAT. Each Industry Member must, however, ensure the methodology used to mask or otherwise transform an account number does not result in a newly created unique identifier or an internal only identifier that can be used to effect a transaction or would not constitute "Customer Account Information" or “Customer Identifying Information” as defined in the CAT NMS Plan. The same guidance would apply to FDIDs representing a Relationship ID. When selecting an FDID, the Industry Member must also ensure that all vendors and systems can support and use the same FDID for a particular trading account in all CAT Transaction Order events requiring an FDID, and that the same FDID associated with the trading account is submitted to the Customer and Account Information System. 

This FAQ was retired on May 5, 2026.

As stated in FAQ M1, given the purpose of the Firm Designated ID (“FDID”) under the CAT NMS Plan, a change/replacement in the Firm Designated ID (FDID) value associated with a particular trading account would only be permissible in certain limited circumstances, such as system migration, change of vendors, change in clearing firm and change in masking methodology.

If an Industry Member has reported an FDID on a Transaction Order event (e.g., MENO, MEOF, MEOT) and subsequently changed the FDID associated with that particular trading account prior to the implementation of full Customer and Account Reporting, the Industry Member has additional obligations as outlined below. The same obligations would apply to an FDID value representing a Relationship Identifier (“Relationship ID”) and Entity Identifier (“Entity ID”).

All Industry Members:

• Must maintain as part of books and records the circumstances necessitating the FDID change/replacement, and make these records available to Regulators upon request. 

In addition: 

Industry Members who have already reported the FDID to CAT CAIS:

• Must report the change of FDID to CAIS. If reporting in schema version 1.0.0 (LTID Account Phase), see Scenario 3.4 (Ending FDID with Replacing Record) of the CAT CAIS Industry Member Reporting Scenarios – LTID Phase. If reporting in schema version 2.0.0, see the scenario titled “FDID Replaced by Another FDID Within the Same Firm” in the CAT CAIS Industry Member Reporting Scenarios – Full CAIS Phase. 

Industry Members who have NOT reported the FDID to CAT CAIS:

• May report both the prior FDID and replacing FDID to CAIS. If reporting in schema version 1.0.0 (LTID Account Phase), see Scenario 3.4 (Ending FDID with Replacing Record) of the CAT CAIS Industry Member Reporting Scenarios– LTID Phase. If reporting in schema version 2.0.0, see the scenario titled “FDID Replaced by Another FDID Within the Same Firm” in the CAT CAIS Industry Member Reporting Scenarios – Full CAIS Phase. While Industry Members are not required to report all FDIDs to CAT CAIS until the implementation of full Customer and Account Reporting, Industry Members may voluntarily do so. Per FAQ Q8, if an Industry Member voluntarily provides such account reporting, the Industry Member is still subject to timely, accurate and complete reporting requirements. See CAT Alerts 2022-01 and 2023-01 for the Full CAIS Implementation Schedule.  
• OR must notify FINRA CAT of FDID changes via the Customer and Account Reporting Disclosure Form. This Form, as well as the standards for submitting it, are outlined in CAT Alert 2021-02 (Standards for Completing the Customer and Account Reporting Disclosure Form). Industry Members choosing this option must also maintain mapping information that links the prior FDID to the replacing FDID and the associated trading account, Relationship ID, or Entity ID. Industry Members must not provide the FDID mapping information to FINRA CAT on the Customer and Account Reporting Disclosure Form, but must maintain such documentation, and make it available to Regulators upon request. 

Note that after implementation of full Customer and Account Reporting, all Industry Members must maintain as part of books and records the circumstances necessitating the FDID change/replacement, and make these records available to Regulators upon request. In addition, all Industry Members must report a change/replacement of FDID value as described in the CAT Reporting Customer and Account Technical Specifications for Industry Members.

This FAQ was retired on May 5, 2026.

No, the firmDesignatedID submitted to CAIS must be the same firmDesignatedID populated on the related Transaction Order event for a specific trading account, Relationship ID or Entity ID. 

Per FAQ M1, given the purpose of the FDID under the CAT NMS Plan, it is important that this identifier be unique, persistent and consistent within the firm and across all vendors and systems the Industry Member may use to report Transaction Order events requiring an FDID to CAT and associated Customer and Account information for the FDID to CAT CAIS, and unique across time.

This FAQ was retired on May 5, 2026. 

The CAT NMS Plan currently requires Industry Members to provide Firm Designated IDs, Customer Account Information and Customer Identifying Information to the CAT.

As set forth in the CAT NMS Plan, a Firm Designated ID is a unique identifier for each trading account designated by Industry Members for purposes of providing data to the CAT, where each such identifier is unique among all identifiers from any given Industry Member for each business date.

Customer Account Information includes, but is not limited to:

• Account number (except in certain circumstances);
• Account type;
• Customer type;
• Date account opened; and
• Large Trader identifier, if applicable.

Customer Identifying Information means information of sufficient detail to identify a Customer, including, but not limited to, (a) with respect to individuals: name, address, date of birth, individual tax payer identification number (“ITIN”)/social security number (“SSN”), individual’s role in the account (e.g., primary holder, joint holder, guardian, trustee, person with the power of attorney); and (b) with respect to legal entities: name, address, Employer Identification Number (“EIN”)/Legal Entity Identifier (“LEI”) or other comparable common entity identifier, if applicable; provided, however, an Industry Member that has an LEI for a Customer must submit that Customer’s LEI in addition to other information of sufficient detail to identify a Customer.

In light of security concerns, however, the Operating Committee is analyzing alternative approaches to providing Customer information.

No, the Participants obtained exemptive relief from the requirement in Rule 613 for a CAT Reporter to report the Customer-ID(s) for each Customer. Instead, the CAT NMS Plan requires Industry Members to report only the Firm Designated ID for each new order submitted to the CAT, rather than the Customer-ID, and the Plan Processor would associate the specific Customers and their Customer-IDs with individual order events based on the reported Firm Designated ID. The Firm Designated ID is a unique identifier for each trading account designated by Industry Members for purposes of providing data to the CAT, where each such identifier is unique among all identifiers from any given Industry Member for each business date.

The reporting of Customer Identifying Information and Customer Account Information consists of two phases, an earlier phase in which Industry Members must report to the CAT certain account information regarding account holders with a Large Trader Identification (LTID) number or an Unidentified Large Trader Identification (ULTID) number pursuant to SEC Rule 13h-1 (collectively called “LTID Account Information”), and a later phase that requires Industry Members to report all Customer Identifying Information and Customer Account Information. Specifically, each Industry Member must report Customer information according to the following milestones:

First Phase - Limited LTID Account Information Reporting 

April 26, 2021| By April 26, 2021, Large Industry Members (which are Industry Members other than Small Industry Members) must report LTID Account Information for FDIDs that have associated LTIDs or ULTIDs and a CAT reporting requirement on or after April 26, 2021. The specific reporting requirements and guidance for such reporting are set forth in the CAT Reporting Customer and Account Information Technical Specifications for Industry Members-LTID.

December 13, 2021| By December 13, 2021, all Industry Members (Large and Small Industry Members) must report LTID Account Information related to all remaining FDIDs that have associated LTIDs or ULTIDs and CAT reportable activity as of and including Phases 2a, 2b, 2c and 2d.

Note that all Industry Members may begin submitting LTID Account Information to the CAT CAIS Testing Environment on August 24, 2020 and to the CAT Production Environment on December 14, 2020.

Second Phase - Full Customer & Account Reporting

May 31, 2024| All Industry Members must report to the CAT a full set of Customer Account Information and Customer Identifying Information for all Active Accounts in Phase 2e. The specific reporting requirements and guidance for Industry Members is provided in the CAT Reporting Customer and Account Technical Specifications for Industry Members-Full CAIS and CAT Alerts 2022-01 and 2023-01.

In addition, on a periodic basis, each Industry Member will be required to submit to the CAT a complete set of all required Customer information.
 

An Industry Member is required to report an LEI for a Customer that is a legal entity to the CAT if the Industry Member has an LEI for a Customer. The CAT NMS Plan does not require a Customer to obtain an LEI if it does not have one, it does not require a Customer to provide an LEI to an Industry Member; and it does not require the Industry Member to request an LEI of its Customer.

The LEI information associated with Customer information is separate from the collection of the Industry Member’s LEI via the CAIS Registration Form and CAT Registration Form (Transaction Reporting). For additional information pertaining to LEI and Industry Members, see FAQs A34 and Q38.

The CAT NMS Plan defines a “Customer” as (a) the account holder(s) of the account at a registered broker-dealer originating the order; and (b) any person from whom the broker-dealer is authorized to accept trading instructions for such account, if different from the account holder(s). This is the same definition as set forth in Rule 613(j)(3).

Industry Members are required to obtain and report LTIDs to CAT for Firm Designated IDs (FDID) with Reportable Events that must be reported to CAT in Phase 2c (equities) and Phase 2d (options). This applies to both existing FDIDs and new FDIDs established after the Phase 2c and 2d implementation dates. Each Industry Member must determine how to obtain the LTID for each FDID – to the extent that an LTID exists – in order to report this information to CAT. This means that CAT imposes new recording and reporting obligations on some Industry Members with respect to obtaining LTIDs to meet their CAT reporting obligations. Some Industry Members may have to change current onboarding activities to ensure an LTID is obtained and recorded for any account with Reportable Events.

Large Industry Members must obtain and report LTIDs to CAT by April 26, 2021 for Phase 2c and December 13, 2021 for Phase 2d. Small Industry Members must obtain and report LTIDs to CAT by December 13, 2021 for both Phase 2c and Phase 2d. 

No. Sensitive Identifiers are defined in the Customer and Account Information Technical Specifications as Social Security Number and Individual Taxpayer Identification Identifiers. Industry Members must not provide Sensitive Identifiers, nor full dates of birth for individuals, nor account numbers for customer accounts to the CAT.  In light of security concerns raised with regard to the maintenance of Customer information in the CAT, the SEC granted exemptive relief on March 17, 2020 that would eliminate the requirement to report these three data elements [

Further, a Sensitive Identifier, date of birth or account number must not be submitted to CAIS as a value for any field in the record including firmDesignatedID and accountName, unless it is masked. In the scenario where a Sensitive Identifier, date of birth or account number is part of the account name in an Industry Member’s books and records, it is expected that the masked accountName value submitted to CAIS will not match the unmasked account name in an Industry Member’s books and records.  

In addition, Industry Members must not submit to CAIS, in any field of the record, any other number associated with the customer’s account that could be used to effect a transaction in the account.
 

Yes, Industry Members may provide Customer Account Information on all of their accounts, not just Active Accounts or those Active Accounts in scope for a given phase of reporting. If an Industry Member voluntarily provides such account reporting, the Industry Member is still subject to timely, accurate and complete reporting requirements. As noted in FAQ Q7, Industry Members must not provide social security numbers, dates of birth and account numbers to the CAT. See CAT Alerts 2022-01 and 2023-01 for the Full CAIS Implementation Schedule.

As described in the Customer and Account Technical Specifications for Industry Members (LTID and Full CAIS), in the scenario a CAT Reporter that is a clearing firm or self-clearing firm determines a person (which includes both natural persons and legal entities under Section 13(h)(8)(E) of the Exchange Act) would qualify as a large trader, but the firm has not yet been provided with an LTID by the person, the clearing firm or self-clearing firm is required to assign an ULTID to the person until such time as the person provides their LTID. Any CAT Reporter that is a clearing firm or self-clearing firm with an obligation to assign an ULTID under the large trader rule is required to report any assigned ULTIDs associated to their FDIDs as part of their customer and account reporting. CAT Reporters that are not clearing firms or self-clearing firms and do not have an obligation to assign ULTIDs are not required to report ULTIDs to CAT as they will have no such number to report.

The ltidEffectiveDate in this scenario is the date the Industry Member was provided the LTID and it was associated with the FDID. If an Industry Member stores LTIDs at the entity, top account or relationship level (for example, in the case of institutional accounts), the ltidEffectiveDate may be reported as the date the Industry Member associated the LTID to the top-level account (for all associated subaccounts) or the entity or relationship level for all associated FDIDs. 

The ltidEndDate is the date the Industry Member became aware that the LTID or ULTID was no longer associated with the FDID.

Industry Members should make a reasonable effort to obtain an accurate reason as to why the LTID, ULTID or Customer is no longer associated to the FDID. Starting with the implementation of Full CAIS, if the facts and circumstances regarding why an association was ended cannot be reasonably ascertained, then the ltidEndReason or roleEndReason value of ‘OTHER’ may be used.

Industry Members must record in their systems the date that an LTID or ULTID becomes associated with an FDID (“LTID Effective Date”). Some Industry Members may have to change current onboarding activities to ensure this information is obtained and recorded. 

If an Industry Member has not recorded the LTID Effective Date, they may use the go-live date as the ltidEffectiveDate until the go-live date. Starting on the go-live date, Industry Members must record and report an accurate LTID Effective Date. 

For information on the relevant go-live dates, see FAQ Q3.

If an LTID to FDID association is ended erroneously and must be reestablished, the Industry Member should populate the ltidEffectiveDate with the original LTID Effective Date- not the date that the record reestablishing the association is submitted to CAT CAIS. 

If an LTID to FDID association is ended for a legitimate reason and must be reestablished, the Industry Member should populate the ltidEffectiveDate with the date on which the LTID or ULTID became re-associated to the FDID within the CAT Reporter’s system- not the original LTID Effective Date. 

For the first phase (Limited LTID Account Information Reporting), starting on April 26, 2021, the Industry Member must also populate ltidEndreasonNull=true and ltidEndDateNull=true with the record reestablishing the LTID to FDID association. Beginning in the second phase (Full Customer and Account Reporting), Industry Members need only leave null or exclude the ltidEndDate and ltidEndReason attributes to clear previously set value.
 

Industry Members may resubmit the same record each business day but are not required to. If an Industry Member resubmits an identical record to one that already exists in CAT CAIS, CAT CAIS will overwrite the previous record with the new record with the same information. 

For the LTID Phase, it was permissible to exclude optional or conditional attributes previously submitted for an FDID or LTID, and no implicit update was made to these values stored in CAIS. If an Industry Member intended to clear a previously submitted value, it was required to use the paired NULL attribute for the field. 

For the Full CAIS Phase, Industry Members are required to include all attributes and associations for each record within the file. Industry Members are still only required to include records in their submission when changes occur to Active Accounts, however each record present in the file must contain the current state of attributes and associations of the record. The sole exception to this inclusion of all current attributes and associations is Customer associations that were previously stored, where the FDID is not included in the current submission but at least one of its associated Customers is included. For example, suppose a Customer Record was associated to both FDID 1234 and FDID 5678 and was previously accepted by CAIS. Later, the Industry Member must submit required updates for FDID 1234 but there were no changes to FDID 5678. All current attributes and associations for FDID 1234 must be reported to CAIS. Despite having a common Customer, the Industry Member is not required to submit all current attributes and associations for FDID 5678 because there are no changes to this FDID. Please see the Customer and Account Technical Specifications for Industry Members- Full CAIS for more information. 
 

Industry Members are only required to report LTIDs for active accounts. That is, accounts for which there is CAT reportable activity.

Account movements must be linked in CAIS beginning in Phase 2e (Full CAIS May 31, 2024).

Periodic Customer Account refreshes were not required in the LTID Phase but are required in the Full CAIS Phase. Note, FDIDs that are accepted in daily submissions will have met the refresh requirement. 

In light of the proposed amendment to the CAT NMS Plan regarding CAIS reporting requirements (see Securities Exchange Act Rel. No. 102665) (https://www.govinfo.gov/content/pkg/FR-2025-03-19/pdf/2025-04516.pdf), compliance with the Periodic Customer & Account Information Refresh has been delayed to a future to-be-determined date.

To provide time for testing ahead of the first Periodic Customer & Account Information Refresh Due Date, the first FDID Refresh Reports were delivered in the Test Environment on December 4, 2024 and will continue to be delivered on the third CAT Trading Day of each following month.

Additionally, the first FDID Refresh Reports were delivered in the Production Environment on January 6, 2025 and will continue to be delivered on the third CAT Trading Day of each following month. The refresh deadline will be reset for FDID Records that are refreshed in the Production Environment. The FDID Refresh Reports are being delivered in the Production Environment for testing purposes and unrefreshed FDIDs may display a Refresh Due Date in the past and a Status of OVERDUE. Since these FDID Refresh Reports are being delivered ahead of compliance with the first Periodic Customer & Account Information Refresh requirement (which, as noted above, has been delayed to a future to-be-determined date), these FDIDs are not subject to the compliance requirement until further notice. 

See the Periodic Customer & Account Information Refresh section of the CAT Reporting Customer and Account Technical Specifications for Industry Members-Full CAIS for more information.    
 

Concurrent with Phase 2c (April 26, 2021), LTIDs or ULTIDs associated with FDIDs must be reported in the LTID Phase of CAIS (“CAIS LTID”) when all three of the following conditions are met:

• a.    The Industry Member is a Large Industry Member (which is an Industry Member other than a Small Industry Member); AND

• b.    The FDID has an associated LTID or ULTID; AND

• c.    The FDID is reported in equities and/or options events to CAT on or after April 26, 2021. CAT Reportable Events requiring an FDID include:

  • i.     New Order, Trade and Order Fulfillment events (MENO, MENOS, MONO, MONOS, MENQ, MEOT, MEOTS, MEOF)

  • ii.    Equity Allocation events (MEPA, MEAA)

For an FDID reported in an equity and/or options event prior to April 26, 2021, the FDID is not required to be reported to CAIS until or unless that FDID is reported in an equity and/or options event occurring on or after April 26, 2021.

For example: 

A Large Industry Member has recorded FDID XYZ456 which has an associated LTID. On February 2, 2021, the Industry Member accepts a GTC order for FDID XYZ456. On April 26, 2021, FDID XYZ456 has no reportable activity even though the GTC order remains active. At 8:30 am ET on April 29, 2021, the GTC order for FDID XYZ456 is executed and reported on an MEOT. The Industry Member now has a CAIS reporting obligation and is required report this FDID and associated LTID information to CAIS no later than 8 am ET on April 30, 2021. For more information on reporting deadlines in the CAIS LTID Phase see FAQ Q21. 

Concurrent with Phase 2d (December 13, 2021), Large Industry Members must report any additional LTIDs or ULTIDs associated with FDIDs that have events reportable to CAT as of and including Phase 2d using the same conditions as above, with the addition of Option Allocation events (MOPA, MOAA).

In addition, Small Industry members must report LTIDs or ULTIDs associated with FDIDs that have events reportable to CAT as of and including Phase 2d using the same conditions as above, with the addition of Option Allocation events (MOPA, MOAA) by December 13, 2021.

NOTE: All firms satisfying the above criteria, including introducing and non-self clearing executing brokers, are required to begin reporting in the CAIS LTID Phase.

For more guidance regarding an LTID or ULTID being associated with an account, contact the SEC or see the SEC’s Large Trader Rule FAQs at https://www.sec.gov/divisions/marketreg/large-trader-faqs.htm.

For both phases, the CAT NMS Plan requires Industry Members to report Received Industry Member Data, which includes customer and account data, by 8:00 a.m. Eastern Time on the CAT Trading Day following the day the Industry Member receives such Received Industry Member Data. See CAT Alerts 2022-01 and 2023-01 for the Full CAIS Implementation Schedule. 

For example:

If the Industry Member receives Received Industry Member Data before 4:15 p.m. ET on T, then the Customer and Account data must be reported by 8:00 a.m. ET on T+1.

If the Industry Member receives Received Industry Member Data after 4:15 p.m. ET on T, then the Customer and Account data must be reported by 8:00 a.m. ET on T+2.

Also, as stated in FAQ Q43, while a firmDesignatedID value of ‘PENDING’ is acceptable for Transaction reporting, CAT CAIS will reject a firmDesignatedID value of ‘PENDING’. Thus, once the FDID becomes available, the Industry Member must report the actual FDID to CAT CAIS along with all other required Customer and Account information by 8:00 a.m. ET on T+1.

Received Industry Member Data not reported within these timeframes will not be marked late by the Plan Processor but will be subject to review by the applicable SRO.

See the Reporting and Repair Deadlines and Examples from the May 4, 2021 CAIS Technical Specification Working Group.
 

Yes. If an LTID or ULTID is associated with an account, it must be reported to CAIS in the LTID Phase. For more guidance regarding an LTID or ULTID being associated with and account, contact the SEC or see the SEC’s Large Trader Rule FAQs. See https://www.sec.gov/divisions/marketreg/large-trader-faqs.htm

Yes. If an introducing broker or non-self-clearing executing broker has Reportable Events for an account with associated LTIDs or ULTIDs, they must report such accounts to CAIS LTID as described in FAQ Q20.

Yes. See the Industry Member CAIS Onboarding Guide for details on production readiness certification.

Yes, all broker-dealers will be required to be certified in order to gain access to the CAIS Production environment. The certification may be supported by their Reporting Agent. See the Industry Member CAIS Onboarding Guide for details on production readiness certification.

Please see the Industry Member CAIS Onboarding Guide for complete details.

For the LTID Phase, Reporting Agents should aggregate the number of accounts with associated LTIDs across all of its broker-dealers (CRDs) it is reporting for. The certification requirements will apply against the aggregate totals of CAIS-reportable accounts with the added requirement that at least one record from every broker-dealer (CRD) that is reportable is included in the certification.

For the Full CAIS Phase, Reporting Agents must provide production data for at least 75% of the FDID population (aggregated across all CAT Reporters for which organization submits data) or 1,000 records, whichever is fewer. In addition, all CAT Customer record(s) corresponding to the submitted FDID records must be provided. Finally, the CAT Customer records for the submitted FDID records must include at least one of each TID Type where the Reporting Agent reports on behalf of a CAT Reporter that has at least one CAT Customer with that TID Type, including:

• SSN/ITIN for a US Natural Person
• EIN for a US Legal Entity
• FOREIGN for a non-US Natural Person or Legal Entity

CAIS LTID opened for Production on December 14, 2020. Once a CAT Reporter was certified, it was enabled to submit into Production. Any data submitted into Production, even before the April 26, 2021 mandatory reporting date, was considered “live” data and any changes to the reportable attributes of that account had to be reported. Certified Reporters were able to “stage” their CAIS LTID data into Production however they wished between December 14, 2020 and April 26, 2021.

See CAT Alerts 2022-01 and 2023-01 for a description of the Full CAIS Implementation Schedule.

Please see the Industry Member CAIS Onboarding Guide for more information.
 

Beginning April 26, 2021, Large Industry Members will be required to report into CAIS LTID all FDIDs with associated LTIDs or ULTIDs with Reportable Activity on or after April 26, 2021. Firms may choose to report accounts without associated LTIDs or ULTIDs, but there is no requirement to do so until the implementation of Full CAIS. See CAT Alerts 2022-01 and 2023-01 for the Full CAIS Implementation Schedule.

Yes. Proprietary trading firms must submit account information related to their own accounts to the CAT CAIS system. If the proprietary trading firm is itself a Large Trader, it is required to report its own accounts beginning with the LTID Phase of CAIS if it has Reportable Activity.

More information can be found at the SEC’s Large Trader Requirements FAQs. See https://www.sec.gov/divisions/marketreg/large-trader-faqs.htm.

Introducing and executing brokers are responsible for reporting the LTID information for the accounts of their clients, where they have reported New Order Events of that client to CAT and the account has an LTID.  For introducing and executing brokers who are self-reporting to CAT, clearing brokers should provide LTID information to those introducing and executing brokers to facilitate the timely and accurate reporting of such information.  For introducing and executing brokers who are not self-reporting to CAT, the clearing broker or any other CAT reporting agent might be engaged to report on their behalf.

Yes, Production data may be submitted to the CAIS Test environment. Optionally, data submitted to the CAIS Test environment can be obfuscated; however it is not required. For more information on testing in the CAT CAIS Test environment, see the Testing section of the CAT Reporting Customer and Account Technical Specifications for Industry Members.

For information on Production Readiness testing and data requirements for the Transaction Portal, see the Industry Member Onboarding Guide.

Because all CAIS data is maintained separately from transaction data for data security reasons, Industry Members are required to establish separate Reporting Relationships for CAIS. It is acceptable to have relationships with the same party for both CAT transaction data and CAIS; however they are separate relationships and will need to be separately established. CAT CAIS Reporting Relationships must be established to authorize another CAT Reporting Agent to submit on a firm’s behalf. Relationships must be established prior to any data submissions to the CAT CAIS Reporter Portal.

Firms transmitting data on their own behalf are not required to establish a relationship for themselves.

LTID identifiers are issued by the SEC. These are not publicly available. 

The requirements are detailed in the CAT CAIS Industry Member Onboarding Guide.

There is no record limit for files submitted to CAT CAIS through SFTP. However, files submitted through SFTP are limited to a maximum uncompressed size of 7GB. Files sizes <= 1GB are recommended as feedback will be returned faster. For more information, see CAIS Technical Specification section 5.1.3 – Data File Submission. Note that the file size recommendations for CAT CAIS are different from the file size recommendations for CAT Transaction reporting.

As explained in FAQs Q6 and Q31, CAT Reporters are required to obtain and report LTIDs to CAT, including introducing brokers and executing brokers that use separate clearing brokers. In contrast, Legal Entity Identifiers (LEIs) are not required to be disclosed to a broker-dealer, nor is a broker-dealer required to obtain an LEI from its customers. Further, there are no obligations imposed by SEC Rule 613 or the CAT NMS Plan to obtain an LEI from a customer for purposes of reporting it to CAT. Therefore, LEIs are only required to be reported to CAT if the CAT Reporter has otherwise obtained an LEI for a particular customer.  

The CAT NMS Plan requires Industry Members to “submit to the Central Repository” information  “including CRD number and LEI, if such LEI has been obtained.” “Central Repository” means the repository responsible for the receipt, consolidation, and retention of all information reported to the CAT pursuant to SEC Rule 613 and this Agreement. 
 
The CAT NMS Plan requirement does not require Industry Members to obtain an LEI, but rather to provide its LEI to the Plan Processor (FINRA CAT) if the Industry Member does have an LEI. The collection of the Industry Member’s LEI via the CAIS Registration Form and CAT Registration Form (Transaction Reporting) are separate from the reporting of customer account LEI data requirements. (For additional information pertaining to the LEI for customer accounts, see FAQs Q1 and Q4).  

Section 1.1 of the CAT NMS Plan defines “Active Accounts” as “an account that has had activity in Eligible Securities within the last six months.” Section 6.4(d)(iv) of the Plan, as well as the SRO CAT Compliance Rules, requires each Industry Member to “submit an initial set of the Customer information… for Active Accounts to the Central Repository [CAIS] upon the Industry Member’s commencement of reporting to the Central Repository [CAIS].”

This reportable activity includes all customer and proprietary accounts with any CAT-reportable events associated with the Firm Designated IDs (FDID), as well as any proprietary accounts for which the Industry Member utilizes the account number as the FDID. All accounts with any CAT-reportable activity on or after June 12, 2022 must be reported to CAIS with the implementation of Phase 2e (Full CAIS). See CAT Alerts 2022-01 and 2023-01 for the Full CAIS Implementation Schedule.

Also see FAQ Q41 regarding changes to customer and account records after June 12, 2022.
 

As outlined in FAQ Q40, all Active Accounts with activity on or after June 12, 2022 must be reported to CAIS with the implementation of Phase 2e (Full CAIS). Industry Members are required to report the current state of the customer information and account records in effect at the time the account is first required to be reported to the CAIS Production Environment. Per CAT Alert 2022-01, subsequent updates and changes to customer and account information must be reported to CAIS no later than November 7, 2022.

For example, a customer relocated from Address A to Address B in August 2022, and is residing at Address B on October 15, 2022 when Industry Member 1 is required to report this record to CAIS. The customer no longer has any association to Address A as of October 15, 2022. In this example, Industry Member 1 would only be required to report the current state of the account and customer information to CAIS (i.e., Address B) on October 15, 2022.
 

Prior to the CAT CAIS Implementation date (May 31, 2024), in this case where there are multiple dates associated with an account, CAT Reporters should report the fdidDate that is reasonably available. See CAT NMS Plan, Article 1, Section 1.1 definition of “Account Effective Date”. For example, if a CAT Reporter has physical account papers located in an offsite storage system and a different systematized date, both of which indicate that the account was opened prior to the CAT CAIS Implementation date, it is reasonable to use the systematized date as the fdidDate.

After the CAT CAIS Implementation date (May 31, 2024), the CAT Reporter must use the date that is reflected in its books and records as the fdidDate.
 

No. CAT CAIS will reject a firmDesignatedID value of ‘PENDING’. Once the FDID becomes available, the Industry Member must report the actual FDID in the firmDesignatedID field to CAT CAIS in the phase in which the Industry Member is required to report FDIDs to CAT CAIS. The CAT NMS Plan requires Industry Members to report Received Industry Member Data, which includes customer and account data, by 8:00 a.m. Eastern Time on the CAT Trading Day following the day the Industry Member receives such Received Industry Member Data. 

Beginning with the implementation of Phase 2e (Full CAIS), the addressList field at the account level is required to be populated for each FDID reported to CAIS. Industry Members must report one mailing address associated with the account in the ‘ADDRESS1’ value of the addrType field. The mailing address submitted is the destination where account correspondence is sent at the account level. In addition to the requirement to distinguish a mailing address for the account, Industry Members have the ability to report an additional three addresses associated with the FDID at the account level via the ‘ADDRESS2’, ‘ADDRESS3’, and ‘ADDRESS4’ values. If multiple addresses are associated with a particular account, then Industry Members must submit these additional addresses to CAIS if such address information is reasonably available. For example, Industry Members that maintain three mailing addresses for a particular account would populate such address information as addrType values of ‘ADDRESS1’, ‘ADDRESS2’, and ‘ADDRESS3’.

As noted in FAQ M12, the Firm Designated ID applies to a trading account, not to a particular Customer. However, in addition to supporting address records maintained at the account level, CAIS supports the ability for Industry Members to report up to four addresses associated with a particular customer record via the addressList field. In instances where an Industry Member maintains separate addresses at the account and customer level, then all such reasonably available addresses must be reported to CAIS.

For more information on the requirements for the data attributes for Customer information pursuant to the CAT NMS Plan, see Sections 9.1 and 9.2 of Appendix D.
 

As noted in FAQ Q44, if multiple addresses are associated with a particular account, then Industry Members must submit these additional addresses to CAIS if such address information is reasonably available. Further, FAQ Q44 states that in instances where an Industry Member maintains separate addresses at the account and customer level, then all such reasonably available addresses must be reported to CAIS.

While various addresses associated with a particular Account or Customer are of regulatory significance, the Plan Participants recognize that Industry Members may save several addresses in their records, some of which may contain legacy information. The requirement to report additional address information maintained by the Industry Member is not intended to change or supersede the Industry Members’ obligations to collect or maintain customer and account address information. Outside of Industry Members’ existing record keeping requirements and applicable SRO and SEC rules, there are no additional CAT CAIS-specific requirements to validate, audit or otherwise update and maintain such additional addresses by or at the time they are initially reported to CAT CAIS along with the full set of Customer and Account information with the implementation of Phase 2e (Full CAIS). Notwithstanding the above, additional addresses should be reported in the appropriate format to CAT CAIS.
 

For Customers with a US Taxpayer Identification Number (for example, social security number), Industry Members must not populate the customerType field with ‘FOREIGN’. ‘FOREIGN’ must only be used if the Customer is a Natural Person or Legal Entity that does not have a US Tax Identifier. Thus, Industry Members must choose one of the other allowable values to represent the CAT Customer associated to the FDID.

For the purposes of CAT CAIS, the value ‘ADVISER’ in the customerType field has the same definition as “Investment Adviser” in Section 202(a)(11) of the Investment Advisers Act of 1940.

Further, a customer is considered associated with a US registered Investment Adviser if they are such a person as defined as “a person associated with an investment adviser” in Section 202(a)(17) of the Investment Advisers Act of 1940.
 

The Industry Member must populate as ‘ADDRESS1’ the same principal business address as is listed on its Uniform Application for Broker-Dealer Registration (or “Form BD”). If the Industry Member listed a separate mailing address on its Form BD, it must populate this address as ‘ADDRESS2’. 

No. An Industry Member would not be required to re-activate a closed FDID in CAIS for post-account closure residual cash payments.  

No. CAT CAIS does not accept the GIIN for the foreignTIDType because the GIIN does not guarantee uniqueness as an Input Identifier to generate a foreignTIDType. Industry Members must obtain either a National Registration or Tax Identifier (‘NATIONALID’), Legal Entity Identifier (‘LEI’), or another Government Issued Identifier (‘OTHGOVT’) from the customer in order to generate a foreignTIDType for a foreign legal entity.

See FAQ Q63 for more information regarding how FDID Records should be reported to CAIS when the account holder is a foreign trust or foreign estate with no Input Identifier.

Prior to the implementation of full Customer and Account Reporting (May 31, 2024), if an Industry Member has not recorded the date on which the Customer entered into the specified role on the account, it may populate the roleStartDate field with a start date that is reasonably available. If no start date is reasonably available, the Industry Member may populate this field with the same value as the fdidDate. For example, if an Industry Member has physical account papers located in an offsite storage system, it is reasonable to use the associated fdidDate as the roleStartDate. Note that the fdidDate may not be used as a default date for the roleStartDate field.  

Starting on May 31, 2024, the Industry Member must populate the roleStartDate field with the date on which the Customer entered into the specified role on the account, according to the Industry Member’s books and records.
 

If the Industry Member’s practice is to close an account and open a new account in the scenario where there is a triggering event, the Industry Member must populate the “end date” fields with the date that is maintained in its books and records.

The updated record is required to be reported to CAT CAIS by 8:00 a.m. Eastern Time on the CAT Trading Day following the day the Industry Member confirmed the date in its books and records.

For example, the date of death of an account holder was January 1. The beneficiary notified the Industry Member on February 1 and requested closure of the account, but did not provide the required documentation (e.g., death certificate) until February 15. On February 16, the Industry Member confirmed the death of the account holder and started processing the account closure. The Industry Member must populate the “end date” fields with the date that is maintained in its books and records. However, the updated record is due by 8:00 a.m. Eastern Time on February 17 (assuming February 17 is a CAT Trading Day).
 

As stated in FAQ B53, transfers of securities during an account transfer between broker-dealers (e.g., ACATS transfers, transferring a Registered Investment Advisor (RIA) book of business from one Industry Member to another Industry Member and for a clearing firm when a correspondent firm changes to another clearing firm) are not orders, as defined by SEC Rule 613. Such account transfer activity as outlined above between Industry Members does not meet the definition of Mass Transfer of FDIDs across CAT Reporter Firms for CAT CAIS reporting requirements. As such, the Industry Member closing the account must populate the value of ‘ENDED’ in the roleEndReason, fdidEndReason, and ltidEndReason fields. The same guidance would apply to a firmDesignatedID (FDID) representing a Relationship ID or Entity ID.

The requirements to report mass transfer of FDIDs across CAT Reporters is limited in scope to mergers, acquisitions, and divestures. Refer to the Full CAIS Technical Specifications for Industry Members for more information.
 

If no address is stored at the FDID level, the Industry Member must choose one mailing address associated with one customer and report it as the mailing address associated to the FDID. Industry Members have the ability to report an additional three addresses associated with the FDID via the ‘ADDRESS2’, ‘ADDRESS3’, and ‘ADDRESS4’ values.

Although a specific methodology is not prescribed for choosing which address(es) to report to CAIS for the FDID, any methodology must be applied consistently by the Industry Member. In addition, the Industry Member must be consistent in its approach and methodology for populating the ‘ADDRESS2’, ‘ADDRESS3’, and ‘ADDRESS4’ values, if populated. Please see FAQs Q44 and Q45 for more information.
 

Resolving a Material Inconsistency requires that a Reporter follow the Material Inconsistencies Procedure as set forth in the Full CAIS Technical Specifications for Industry Members to confirm or correct the record that generated the Material Inconsistency. The Material Inconsistencies Procedure does not require the Reporter to contact the Customer to confirm the Customer’s information. For more information on Material Inconsistencies, see the Material Inconsistencies section of the Full CAIS Technical Specifications for Industry Members. 

The Industry Member is required to report Customer information for the entity authorized trader for this account to the CAT.  The Industry Member is not required to report Customer information for any natural persons who are employed by the entity authorized trader and who are authorized to trade for that account on behalf of the entity authorized trader, unless the account holder specifically designates the natural person employee as authorized to trade for the account independent of the authority granted to the entity authorized trader, in which case the Industry Member is also required to report Customer information for that natural person authorized trader to the CAT.  These requirements apply regardless of whether the account holder is a natural person or a legal entity.  

This FAQ response is based on the SEC Staff’s interpretation of the definition of “Customer” in Rule 613(j)(3) that natural persons who are employed by, and authorized to trade for an account on behalf of, an entity authorized trader are not considered different from the entity authorized trader.  The SEC Staff’s interpretation is similar to and consistent with the guidance provided by the SEC in footnote 388 of the Rule 613 Adopting Release, which states that “for the purposes of Rule 613(j)(3), natural persons who are employed by an entity that is an account holder, and who are authorized to trade for that account, are not considered different from the account holders, and are therefore not covered by Rule 613(j)(3)(ii).”   
 

In the event that a CAT Reporter has multiple valid Input Identifiers for a CAT Customer who is associated with a single account at the firm, then the CAT Reporter will need to select one of the Input Identifiers based on the following criteria. 

If there is more than one Input Identifier type for the CAT Customer, then CAT Reporter Firms must follow the hierarchy as outlined in Section 2.2.5 of the Full CAIS Technical Specifications for Industry Members. Specifically, if a US-assigned Input Identifier (i.e., SSN/ITIN or EIN) is available for the CAT Customer, then the CAT Customer must be reported to CAIS using a Transformed Identifier (TID) generated from the US-assigned Input Identifier. 

• For example, a dual citizen Natural Person CAT Customer provides a CAT Reporter with both a valid SSN and a National Identity Card for a country outside of the United States. In this example, the CAT Reporter firm would generate the TID value from the SSN. 

In the event the CAT Customer does not have a US-assigned Input Identifier but has more than one foreign Input Identifier of a specific type– such as multiple Tax Identifiers or multiple Legal Entity Identifiers (LEI) values – then the CAT Reporter Firm must determine which value is the primary, current value. If multiple values are current, the CAT Reporter firm must select the Input Identifier from the country/municipality of the primary incorporation or residence of the customer.

• For example, a Legal Entity CAT Customer is currently legally registered in both the United Kingdom and France, and provides the CAT Reporter with a Tax Identifier for both locations. The Customer indicates and/or the CAT Reporter ascertains that the United Kingdom is the primary incorporation of the Legal Entity.  In this example, the CAT Reporter would use the Tax Identifier for the United Kingdom to generate the TID value.
   

As noted above, the Full CAIS Technical Specifications require the Natural Person first and last names be reported in two separate fields. In the scenario where the Industry Member has historically maintained the Customer name in an unparsed state and will not be able to complete parsing of all Customer names by the implementation schedule set forth in CAT Alerts 2022-01 and 2023-01, the Plan Participants will temporarily make available a value of ‘UNPARSED’ to be populated in the firstName field. The unparsed name must be populated in the lastName field. Further, as soon as practicable, but no later than June 12, 2023, the Industry Member must resubmit the Customer Record to CAIS with the first and last names parsed and in the required separate firstName and lastName fields.

Use of the ‘UNPARSED’ value in the firstName field is only allowable until June 12, 2023. While the Plan Participants are providing this temporary solution to allow Industry Members to report the Customer Record to CAIS according to the implementation schedule set forth in CAT Alerts 2022-01 and 2023-01, an unparsed first and last name is not in compliance with the Plan and the Operating Committee-approved Technical Specifications which require that the first and last names be reported in separate fields. There is no exemptive relief that would allow the entry of Customer names in an unparsed state. Accordingly, use of the ‘UNPARSED’ value could be subject to review by Regulators.

An “Unparsed Names” Report will be made available to regulators and affected Industry Members. ‘UNPARSED’ will be retired from the Full CAIS Technical Specifications effective June 13, 2023.
 

All accounts, Relationships or Entity IDs (as represented by the FDID/Firm Designated ID) with any CAT-reportable activity (equities, options and/or multileg events) on or after June 12, 2022 must be reported to CAIS with the implementation of Phase 2e (Full CAIS). See CAT Alerts 2022-01 and 2023-01 for the Full CAIS Implementation Schedule. 

Example 1 (FDID in scope for Full CAIS reporting)

On June 22, 2020 (the Phase 2a Go-Live date), FRMA had an obligation to report a New Order event (MENO). The order remained open until August 17, 2022, when it was cancelled. Because the FDID had CAT-reportable activity after June 12, 2022, FRMA has a CAIS reporting obligation for this FDID. By contrast, if the open order did not have any subsequent CAT-reportable activity as of the date that FRMA was required to report this FDID to Full CAIS, FRMA would not have a CAIS reporting obligation for this FDID at that time.

Example 2 (FDID in scope for Full CAIS reporting)

FRMB received a customer order on June 12, 2022 and reported a MENO. The account was permanently closed off FRMB’s books on July 1, 2022. FRMB has a CAIS reporting obligation for this FDID because it had CAT-reportable activity on June 12, 2022. When FRMB is required to report this FDID to Full CAIS, it must submit this FDID Record with an fdidEndReason of ‘ENDED’ and fdidEndDate of July 1, 2022.

Example 3 (FDID NOT in scope for Full CAIS reporting)

FRMC is a clearing firm with an obligation to report post-trade allocation events (MEPA/MEAA/MOPA/MOAA). On June 22, 2021, FRMC allocated shares to FDID1234. As of June 12, 2022, there has been no further CAT-reportable activity for this FDID. Since there has been no CAT-reportable activity related to the FDID on or after June 12, 2022, FRMC does not have a CAIS reporting obligation for this FDID. However, should FDID1234 subsequently have any CAT-reportable activity, it will be in scope for Full CAIS reporting.

Example 4 (Business Model with no Full CAIS reporting obligation)

FRMD only accepts orders from other CAT Reporters and immediately routes them away for execution. Since FRMD only reports order accepted events (MEOA/MOOA/MLOA) and order route events (MEOR/MOOR/MLOR) which do not have the firmDesignatedID field on them, FRMD does not have a CAIS reporting obligation for this business model. However, if FRMD has firm-owned/controlled accounts (such as an error account) with activity on or after June 12, 2022, FRMD would have a CAIS reporting obligation for those firm-owned/controlled accounts.
 

Whether the Industry Member should be identified as a CAT Customer depends on whether the Industry Member is an account holder or has authority to place orders for the account without prior approval of the account holder(s). Absent this authority from the account holder(s) (and assuming the Industry Member is not an account holder in this scenario), receipt of a “Not Held” order does not require that the Industry Member be identified as a CAT Customer on the related FDID Record.

See FAQ Q56 for more information regarding when a natural person who is employed by an Authorized Trader must be identified as a CAT Customer.
 

Whether the Industry Member should be identified as a CAT Customer on the FDID Record depends on whether the Industry Member is an account holder or has authority to place orders for the account without prior approval of the account holder(s). Absent this authority from the account holder(s) (and assuming the Industry Member is not an account holder in this scenario), the Industry Member is not required to be identified as a CAT Customer on the related FDID Record when there are standing instructions on the account (such as the Industry Member purchase of shares in an Automated Investment Plan or Dividend Reinvestment Plan) or when an order is placed by the Industry Member to satisfy a legal requirement or SEC/SRO rule, such as a liquidation to satisfy a margin call. In addition, assuming the Industry Member is not an account holder and has not been given authority to place orders for the account without prior approval of the account holder(s), the Industry Member is not required to be identified as a CAT Customer on the related FDID Record when liquidating fractional shares held in a Customer’s account to facilitate operational processes (e.g., ACAT, an Industry Member buying a fractional share from a customer upon receipt of an order to exit its entire position in a security, or orphaned fractional positions). If an Industry Member uses a firm owned or controlled account to trade fractional positions against a Customer account, the Industry Member must report that firm owned or controlled account to CAIS. 

See the section titled “Fractional Share Scenarios” in the CAT Industry Member Reporting Scenarios document for more information regarding the transaction reporting requirements for fractional share scenarios.

See FAQ Q56 for more information regarding when a natural person who is employed by an Authorized Trader must be identified as a CAT Customer.

Yes. When reporting its version of the Customer Record, the clearing firm may replicate the attribute value for certain required data elements as provided by its correspondent firm. Specifically, when the correspondentCRD field is populated, the clearing firm may report a role of ‘AUTHREP’ for an Authorized Trader rather than “flipping” the role to ‘AUTH3RD’ on the clearing firm’s version of the Customer Record. Additionally, when the correspondentCRD field is populated, the clearing firm may report a customerType of ‘EMPLOYEE’ rather than “flipping” the customerType to ‘OTHBKR’ on the clearing firm’s version of the Customer Record.

In limited circumstances where a Legal Entity meets the following criteria:

• Foreign trust or foreign estate; and
• No allowable Input Identifier exists because the foreign country or foreign municipality does not require or issue any kind of identifier; and no LEI is assigned to the entity

The FDID Record may be reported to CAIS with no Customer Record for the foreign trust or foreign estate. However, all other CAT Customers (e.g., trustees that are Authorized Traders on the account) must be reported to CAIS with the customerType value of ‘TRUST’.  Additional information regarding the foreign trust or foreign estate may be required in future phases of CAT.

The above guidance must not be used in instances where an allowable Input Identifier value exists for the foreign trust or foreign estate (e.g., the foreign trust has a foreign Tax Identifier issued by a governmental authority, or an LEI issued by a Local Operating Unit), and only exclusively in those circumstances where no such value exists for the foreign trust or foreign estate.

When reporting an FDID Record for an account that is owned or controlled by an introducing broker/correspondent, it is acceptable for the clearing firm to report the accountType from the perspective of the introducing broker/correspondent. For example, if a clearing firm is optionally reporting the allocation of shares to an error account that is owned/controlled by a correspondent, and the account involved is marked as an error account in the clearing firm’s books and records, the clearing firm must populate the accountType field with ‘ERROR’ (Error account) indicating that the error account is owned/controlled by the correspondent. If the specific type of account involved in the allocation is not recorded in the clearing firm’s books and records, the clearing firm must populate the accountType field with ‘FIRM’ indicating an account owned by the correspondent. 

In the scenario where an Industry Member has systematized all data required to report a Natural Person Authorized Trader, it must report all information required for a complete Customer Record, including tidValue and yearOfBirth. However, in the scenario where an Industry Member has not historically collected and systematized all data required to report a Natural Person Authorized Trader and will not be able to collect and systematize the data by the Full CAIS Compliance Go-Live date per the implementation schedule as set forth in CAT Alerts – 2022-01 and 2023-01, the Plan Participants will have temporarily made available an Authorized Trader Names List on the FDID Record.

The Authorized Trader Names List will enable the Industry Member to report only the name of the Natural Person Authorized Trader having authority to trade on the Account, where they do not have all data required to report the Authorized Trader as a Natural Person CAT Customer. Each FDID submitted must still have at least one active association to a CAT Customer reported with a TID and all required data, with trading capabilities.

Use of the Authorized Trader Names List is only allowable on a temporary basis and, with sufficient time and notice, will be retired from the Full CAIS Technical Specifications at a future date. Thus, Industry Members will be required to resubmit the FDID Record to CAIS with all required data for a full CAT Customer Record.

While the Plan Participants are providing this temporary technical solution to allow an Industry Member to report an incomplete Customer Record for a Natural Person Authorized Trader to CAIS effective with the implementation of full Customer and Account Reporting (in lieu of having that Customer Record rejected), use of the Authorized Trader Names List is not in compliance with the Plan. There currently is no exemptive relief that would allow only the submission of an incomplete Customer Record for a Natural Person Authorized Trader. Use of the Authorized Trader Names List rather than the submission of all information required for Natural Person Authorized Traders could be subject to review by Regulators. Accordingly, Industry Members are encouraged to report all data required for Natural Person Authorized Traders as soon as possible before the Full CAIS Compliance Go-Live date.

The requirement to report to CAT CAIS a firstName, lastName, yearOfBirth, tidType and tidValue (i.e., a hashed version of an Input Identifier, such as a social security number) for all Natural Person Authorized Traders means that CAT may impose new recording and reporting obligations on some Industry Members with respect to obtaining Customer information to meet their CAT reporting obligations. Some Industry Members may have to change current onboarding activities to ensure Customer information is obtained and recorded for any Active Accounts with CAT Reportable Events, including for accounts that existed prior to the effective date of the CAT NMS Plan.
 

If an Industry Member optionally reports a DVP/RVP account that is temporarily not assigned a clearing number or DTC number because the account is new, or the current clearing number or DTC number has been removed from DTCC's ALERT service and no new clearing number or DTC number is available, the Industry Member must populate the DVPCustodianID field with ‘DTCRM’. Further, the DVPCustodianID must be immediately updated upon receipt of the new clearing number or DTC number.

The CAT NMS Plan requires that Industry Members report addresses at the Customer level. In response to industry feedback that broker-dealers generally maintain addresses at the account level rather than at the Customer level, Participants implemented a temporary technical solution that allowed a Customer to be reported to CAIS without an address and permitted Industry Members to report a minimum of one address for each account rather than an address for each Customer.

On September 13, 2021, the Participants requested exemptive relief from the requirement that Industry Members report addresses at the Customer level. The Commission has not acted on this request. Accordingly, there is no exemptive relief that would allow an Industry Member to report only addresses at the account level.

Therefore, effective July 12, 2023, each Customer must be reported to CAIS with at least one address (up to four addresses), and the requirement to report at least one address at the FDID level will remain. Further, Industry Members that reported Customers to CAIS without a Customer level address must report a Customer level address for such Customers to CAIS by no later than July 12, 2023.

Separately, effective August 7, 2023 in the Production Environment, a new validation will reject Customer Records submitted to CAIS without at least one address reported at the Customer level. Error Code 22514, which is currently in production, will be enhanced to cover this new validation on a go-forward basis.

In this situation, the minor or incapacitated person must be reported to CAIS with a role of ‘TRDHOLDER’ with the doingBusinessAs field populated with the value of ‘PUBLIC ADMINISTRATOR’. The Authorized Traders Names List must be included with the submission, and include the name of the government employee public administrator (e.g., U.S. state, county or municipality government employee). 

It is understood by the Plan Participants that a Customer Record with a role of ‘TRDHOLDER’ paired with the ‘PUBLIC ADMINISTRATOR’ value populated in the doingBusinessAs field represents a minor or incapacitated account holder who does not have authorization to trade on the account, and that the associated FDID Record is associated with a government employee Authorized Trader acting in the capacity as of a conservator or guardian for the account holder. This is an interim technical solution to allow these FDIDs to be accepted into CAIS prior to Full CAIS Compliance go-live. This guidance is specific to the scenario where the Natural Person government employee (rather than the Legal Entity) is appointed as the Authorized Trader.

The Industry Member may choose to report such Customer Records to CAIS in the manner outlined above so that the associated FDID Records can be accepted into CAIS and not be rejected due to Error Code 22071. However, given the limited number of FDID Records associated with this guardianship/conservatorship and government employee Authorized Trader fact-pattern, the Industry Member may also opt to resubmit such records to CAIS in the manner described above to CAIS following receipt of Error Code 22071 in its feedback. There currently is no exemptive relief that would allow an Industry Member not to report Customer Identifying Information for U.S. government employee Authorized Traders under Rule 613. In this situation, where the government employee Authorized Trader does not provide a year of birth or Input Identifier citing exemptions from the definition of “customer” under the Customer Identification Program Rule (31 CFR § 1023.100(d)), the Plan Participants are providing a temporary technical solution to allow an Industry Member to report the government employee Authorized Trader in the Authorized Trader Names List, rather than reporting a Customer Record. As noted in FAQ Q65, use of the Authorized Trader Names List is not in compliance with the Plan, is only allowable on a temporary basis and, with sufficient time and notice, will be retired from the Full CAIS Technical Specifications at a future date. Thus, Industry Members will be required to resubmit the FDID Record to CAIS with all required data for a full CAT Customer Record.

The Plan Participants will provide further guidance on this scenario before retirement of the Authorized Trader Names List and are evaluating the mechanism for reporting government employee public administrators to CAIS.
 

Per the Full CAIS Technical Specifications, each CAT Customer must only have one active role in association to the FDID at a time. Therefore, an attempt to associate two or more active CAT Customers with the same EIN to the same FDID will result in a rejection.

A disregarded entity is an entity that is disregarded as separate from its owner for federal income tax purposes. When a disregarded entity and its parent company have the same EIN and are both CAT Customers associated to the same FDID, Industry Members must report only one version of the Customer in association to the FDID, either the disregarded entity or the parent company. The CAT Customer must be identified in a role of ‘TRDHOLDER’, which indicates that the CAT Customer is a holder of the account that also has authorization to trade on the account. The data elements reported to CAIS (e.g., Address, Legal Name, LEI, etc.) in association with the Customer Record must be that of the chosen version of the CAT Customer. For example, when the disregarded entity and its parent company have the same EIN but different LEIs, and the Industry Member has reported the parent company as the CAT Customer associated to the FDID, the Industry Member must report the LEI of the parent company. See also FAQ Q4 for additional information regarding the reporting of LEIs for CAT Customers.

While the Plan Participants are providing this temporary solution to facilitate the partial reporting of Customer information to CAT in the context of disregarded entities, the reporting of only one CAT Customer where two CAT Customers are associated to the same FDID is not in compliance with the Plan. Accordingly, the Plan Participants have requested a temporary exemption from the SEC with respect to certain provisions of the CAT NMS Plan relating to this scenario. The reporting of both the disregarded entity and its parent company as CAT Customers associated to the same FDID may be required in future phases of CAT. 

When the disregarded entity and its parent company have different EINs and are both CAT Customers associated to the same FDID, Industry Members must report both versions of the Customers in association to the FDID. 

When the piggyback firm is fully disclosed, the correspondentCRD field must be populated with the CRD number of the introducing firm that has the relationship with the customer. For example, in a piggyback scenario where the piggyback firm is fully disclosed and Firm A (with customer relationships) piggybacks on Firm B’s clearing relationship with Clearing Firm C, the clearing firm must populate Firm A’s CRD number in the correspondentCRD field. 

See also FAQ U13 for additional information on allocation reporting for piggyback clearing scenarios.

Per the Full CAIS Technical Specifications, each CAT Customer must only have one active role in association to the FDID at a time. Therefore, an attempt to associate two or more active CAT Customers with the same SSN to the same FDID will result in a rejection.

When multiple trusts (or sole proprietorships) and a Natural Person have the same Tax Identifier (i.e., SSN) and are all CAT Customers associated to the same FDID, Industry Members must report only the Natural Person in association to the FDID with the doingBusinessAs field populated with only one of the trusts that shares the Natural Person’s SSN. The Natural Person must be identified in a role of ‘TRDHOLDER’, which indicates that the CAT Customer is a holder of the account that also has authorization to trade on the account. The Plan Participants are not prescribing a specific methodology for which trust must be reported in the doingBusinessAs field, and any methodology must be applied consistently by the Industry Member.

While the Plan Participants are providing this temporary solution to facilitate the partial reporting of Customer information to CAT, the reporting of only one CAT Customer where two or more CAT Customers are associated to the same FDID is not in compliance with the Plan. The reporting of the Natural Person and trusts with the same SSN as CAT Customers associated to the same FDID may be required in future phases of CAT.

When the trusts and Natural Person have different Tax Identifiers and are all CAT Customers associated to the same FDID, Industry Members must report all versions of the CAT Customers in association to the FDID.

In a Mass Transfer scenario, an “Active Account” is reportable to CAIS once there is Transaction-reportable activity for the FDID under the acquiring Industry Member’s CRD number. The Mass Transfer must be reported in accordance with the guidance in the Full CAIS Technical Specifications for Industry Members, including all applicable fields (e.g., priorCATReporterCRD and priorCATReporterFDID). The FDID must be reported to CAIS by 8 am ET on T+1 where T represents the CAT Trading Day of the Transaction-reportable activity. 

For example, if an FDID was acquired on calendar date October 1, but did not have any Transaction-reportable activity until CAT Trading Day November 15, the FDID is required to be reported to CAIS by 8 am ET on November 16 (assuming November 16 is a CAT Trading Day). 
 

The CAT NMS Plan requires the Plan Processor, subject to the oversight of the Operating Committee, to develop a comprehensive information security program that addresses the security and confidentiality of all information accessible from the CAT and the operational risks associated with accessing the CAT. Appendix D of the CAT NMS Plan sets forth minimum data security requirements for the CAT that the Plan Processor must meet. In addition, as required by the Plan, the Plan Processor has designated a Chief Information Security Officer (CISO), who is responsible for, among other things, creating and enforcing appropriate policies, procedures, and control structures regarding data security.

This FAQ was retired on January 29, 2025.

Yes, the CAT is considered an SCI System and it must be operated in compliance with the requirements in Reg SCI applicable to an SCI System. In addition, the CAT NMS Plan requires the Technical Specifications to satisfy all applicable regulations regarding database security including provisions of Reg SCI.

This FAQ was retired on January 29, 2025.

The Consolidated Audit Trail, or “CAT,” is being developed by the national securities exchanges – BOX Exchange LLC, Cboe BYX Exchange, Inc., Cboe BZX Exchange, Inc., Cboe EDGA Exchange, Inc., Cboe EDGX Exchange, Inc., Cboe C2 Exchange, Inc., Cboe Exchange, Inc., Investors’ Exchange LLC, Long-Term Stock Exchange, Inc., Miami International Securities Exchange LLC, MIAX Emerald, LLC, MIAX PEARL, LLC, NASDAQ BX, Inc., Nasdaq GEMX, LLC, Nasdaq ISE, LLC, Nasdaq MRX, LLC, NASDAQ PHLX LLC, The NASDAQ Stock Market LLC, New York Stock Exchange LLC, NYSE American LLC, NYSE Arca, Inc., NYSE Chicago, Inc. and NYSE National, Inc. – and the Financial Industry Regulatory Authority (“FINRA”), a national securities association (collectively, the “Participants”), pursuant to SEC Rule 613. Consolidated Audit Trail, LLC (“CATLLC”) is the entity organized by the Participants to create, implement and maintain the CAT. Broker-dealers (called “Industry Members” under the CAT NMS Plan), exchanges and FINRA will be required to submit customer, order and trade information in “NMS Securities” (i.e., exchange listed stocks and options) and “OTC Equity Securities” (i.e., over-the-counter stocks), across all markets to the CAT Central Repository. The system is designed to permit the SEC and Participants to more effectively and efficiently regulate the securities markets.

This FAQ was retired on January 29, 2025.

Pursuant to the CAT NMS Plan, Customer Account Information generally includes, account number, account type, customer type, date account opened, and large trader identifier (if applicable). Customer Identifying Information means information of sufficient detail to identify a customer. The CAT NMS Plan currently requires that if the customer is an individual, the Customer Identifying Information includes the individual’s name, address, date of birth, individual tax payer identification number/social security number, and individual’s role in the account (e.g., primary holder, joint holder, guardian, trustee person with the power of attorney). If the customer is a legal entity, the Customer Identifying Information includes the legal entity’s name, address, Employer Identification Number/Legal Entity Identifier (“LEI”) or other comparable common entity identifier (if applicable), provided, however, that an Industry Member that has an LEI for a customer must submit the customer’s LEI in addition to other information of sufficient detail to identify a customer. As discussed below in FAQ S7, the Participants requested an exemption from the SEC from certain provisions of the CAT NMS Plan so that social security numbers/taxpayer identification numbers, dates of birth and account numbers of individual customers would not be reported to the CAT Central Repository.

This FAQ was retired on January 29, 2025.

The Participants requested an exemption from the SEC from certain provisions of the CAT NMS Plan so that social security numbers/taxpayer identification numbers for natural persons would not be reported to the CAT. If the exemption is granted, the Plan Processor will generate a unique CAT Customer ID (“CCID”) using a strategy developed in collaboration with Industry Members. The CCID strategy uses a two-phase transformation that avoids the receipt or retention of social security numbers or individual taxpayer identification numbers in the CAT. Industry Members will not receive the generated CCID. The resultant CCID and an associated Firm Designated ID (“FDID”) will be stored by the Plan Processor for further processing. As noted above, the Participants requested an exemption from the SEC from certain provisions of the CAT NMS Plan so that the dates of birth and account numbers of individual customers would not be reported to the CAT Central Repository. Instead of reporting dates of birth and account numbers for individuals, Industry Members would report to the CAT years of birth and FDIDs for accounts for individuals.  

This FAQ was retired on January 29, 2025.

The CAT NMS Plan states that the Plan Processor must provide Participants’ regulatory staff and the SEC with access to all CAT Data for regulatory purposes only. The CAT NMS Plan also states that Participants’ regulatory staff and the SEC will access CAT Data to perform functions, including economic analyses, market structure analyses, market surveillance, investigations, and examinations. Under the CAT NMS Plan, Participants are required to implement effective information barriers between their regulatory and non-regulatory staff with regard to access and use of CAT Data stored in the Central Repository, and Participants may not use CAT Data for commercial purposes. However, the CAT NMS Plan provides that a Participant will be permitted to use the data that it reports to the CAT System for any lawful purpose, including commercial purposes (e.g., to develop new order types).

This FAQ was retired on January 29, 2025.

CATLLC’s actions in the event of unauthorized access to CAT Data will depend on the circumstances. If CATLLC becomes aware of actual (or potential) unauthorized access to CAT Data, CATLLC, working with the Plan Processor, will take all reasonable steps to investigate the incident, mitigate potential harm from the unauthorized access and protect the integrity of the CAT System. CATLLC also will report unauthorized access to law enforcement, the SEC and other authorities as required or as it deems appropriate. CATLLC will notify other parties of unauthorized access to CAT Data where required by law and as it otherwise deems appropriate. CAT LLC will maintain insurance that is required by law. Additionally, the Plan Processor maintains certain insurance.

This FAQ was retired on January 29, 2025.

No. If an Industry Member or CAT Reporting Agent coded a role of ‘AUTH3RD’ for the scenario where the reporting Industry Member itself has authority to place orders for the Account without prior approval of the account holder(s) and is not the holder of the account, the Industry Member and/or its CAT Reporting Agent can certify for Full CAIS production with the previous description of the ‘AUTH3RD’ value, assuming the Industry Member and/or its CAT Reporting Agent meet the production readiness requirements as set forth in the Industry Member CAIS Onboarding Guide. However, effective June 12, 2023, the role field must be accurately populated with ‘AUTHREP’ as set forth in the Full CAIS Technical Specifications.

This FAQ was retired on May 5, 2026. 

A firm may file a fee dispute by submitting a written application to the FINRA CAT Helpdesk at [email protected] within 15 business days after being notified of such disputed CAT fees. The application is required to identify the disputed CAT fees, state the specific reasons why the applicant takes exception to such CAT fees, and set forth the relief sought. FINRA CAT will forward all fee dispute applications to CATLLC. For more information on fee dispute resolution procedures, please see the “CAT Compliance Rule” provisions on fee dispute resolution that are set out in each of the Participants’ rulebooks (e.g. FINRA Rule 6898).

This FAQ was retired on October 28, 2024.