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A. General
A10. How is the cost of the CAT being funded?
Updated:

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have filed fee filings with the SEC to impose CAT Fees on Participants and Industry Members, the Participants have withdrawn these fee filings at this time.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.

A21. Will the CAT be ready to accept Industry Member Data in November 2018? If not, when will Industry Members be required to begin reporting to the CAT?
Updated:

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.

B. Reporting Requirements
B7. If a Reportable Event is priced in a non-U.S. dollar currency, how will such prices be reported to the CAT?
Updated:

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.

B46. The newOrderFDID field in the Post-Trade Allocation Event (MEPA) and Amended Allocation Event (MEAA) is described as “The FDID of the related New Order event, if available in the booking system.” What does “if available in the booking system” mean?
Updated:

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.

B49. Are Industry Members that are a clearing firm required to report the booking of shares into a customer account that result from an options exercise or assignment to CAT?
Updated:

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.

B54. Do the timestamps captured in CAT have to equal the timestamps captured in OATS? For example, if a firm’s system captures nanoseconds, but timestamps are reported to OATS in milliseconds, should the timestamp reported to CAT be captured in nanoseconds?
Updated:

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.

D. Order Receipt
D28. How should orderType be populated for orders that are received or originated without a specific limit price, but that do not have special handling instructions that include pricing criteria and are not market orders? For example, an order is originated to represent multiple customer orders, but does not have a set limit price.
Updated:

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.

E. Order Routing and Execution
E5. How should orders routed to another market participant but not accepted by that market participant be reported to CAT?
Updated:

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.

E8. How should the orderType on the Order Route Event be populated for orders routed as Stop or Stop Limit orders?
Updated:

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.

E9. How should the orderType field be populated for orders that are not market orders, but are not received/originated or routed with a specific limit price?
Added:

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.

E18. Should baskets submitted to NYSE’s Crossing Session II be reported to CAT as an Order Route event or a Trade Event?
Added:

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.

K. Options
K7. When an Industry Member receives a complex order involving both an equity leg and an options leg and solicits interest in the execution of the order, are the solicitation and the responses to the solicitation for the equity leg reportable in Phase 2a?
Added:

The Industry Member that received the original complex order must report the receipt of the equity leg in Phase 2a. Industry Members providing responses to the solicitation of interest do not have any reporting requirements for the equity leg in Phase 2a. Any routing of the equity leg of the complex order to an exchange would be reportable in Phase 2a while the route of the options leg as a complex order would not be reportable until Phase 2d. Potential Phase 2c and 2d reporting requirements for Industry Members providing responses to solicitations are currently under consideration by the Participants for both equities and options.