A registered investment advisor (RIA) operates within a US registered broker-dealer BD1 (i.e., BD1 and RIA are part of the same legal entity). The RIA originates and routes orders for execution away from BD1. What are the RIA's CAT reporting obligations?
Because the RIA is part of the same legal entity as the US registered broker-dealer, orders received or originated by the RIA are subject to all applicable CAT reporting rules and the US registered broker-dealer must report to CAT all orders that the RIA receives or originates. If the RIA were a separate legal entity that was not a member of a US registered broker-dealer, the RIA would not have an obligation to report orders originated and routed by the RIA to the CAT (also see FAQ B55).