The answer is divided into two sections: one section for verbal or manual bids or offers and one section for electronic bids or offers.

• 1. Verbal and Manual Bids and Offers: As stated in FAQ B43, pursuant to the SEC’s July 28, 2023 order granting a temporary conditional exemption, verbal or manual quotes on an exchange floor or in the over-the-counter market are not reportable during Phases 2a, 2b, 2c or 2d. However, this activity will be required to be reported in future phases of CAT, as this temporary exemptive relief expires on July 31, 2026. See CAT FAQ C-7 for additional information on orders considered “manual” or “electronic” for purposes of reporting to the CAT. The CAT reporting requirements for verbal and manual quotes for later phases remains under discussion by the SROs.
• 2. Electronic Bids and Offers: Electronic quotes which are provided by or received in a CAT Reporter’s order/quote handling or execution systems in CAT reportable securities and are provided by an Industry Member to other market participants off a national securities exchange are reportable in Phase 2d for both equities and options under these three conditions:
  • a) An equity bid or offer is displayed publicly or has been communicated (1) for listed securities to the Alternative Display Facility (ADF) operated by FINRA; or (2) for unlisted equity securities to an “inter-dealer quotation system” as defined in FINRA Rule 6420(c);
    
    There are a few important notes about quotes in OTC Equity Securities:
    • i. OTC Equity Securities quotes which are received by an Industry Member CAT Reporter operating an inter-dealer quotation system are reportable in Phase 2a by the operator of the inter-dealer quotation system.
    • ii. OTC Equity Securities quotes sent by an Industry Member to an inter-dealer quotation system operated by an Industry Member CAT Reporter are reportable by the Industry Member sending them in Phase 2d.
    • iii. OTC Equity Securities quotes sent by an Industry Member to a quotation venue not operated by an Industry Member CAT Reporter or SRO are reportable in Phase 2a by the Industry Member. Note that as of this writing, the Participants are not aware of the operation of any such quotation venue.
       
  • b) Or, an equity bid or offer which is accessible electronically by customers or other market participants and is immediately actionable for execution or routing; i.e., no further action is required by the market participant providing the quote before a trade or route can occur.
  • c) Or, a listed option bid or offer which is accessible electronically by customers or other market participants and is immediately actionable for routing to another broker-dealer or to an exchange or exchange floor for execution/representation; i.e., no further action is required by the market participant providing the quote before routing to another broker-dealer or an exchange or exchange floor can occur.

Note that as stated in FAQ B6, CAT Reporters are not required to report to the CAT quotes received via subscriptions to receive market data from market data vendors.