Pursuant to Section 6.3(d) of the CAT NMS Plan (“Plan”), as applied to Industry Members by Section 6.4(d) of the Plan, Industry Members must report certain details to the CAT for each order and reportable event. These requirements are applied to Industry Members via each Plan Participant’s CAT Compliance Rules. 

“Order,” as used in the Plan and the CAT Compliance Rules, is defined by SEC Rule 613(j)(8) to include “[a]ny order received by a member of a national securities exchange or national securities association from any person; [a]ny order originated by a member of a national securities exchange or national securities association; or [a]ny bid or offer.” SEC Rule 300 more specifically defines “order” as “any firm indication of a willingness to buy or sell a security, as either principal or agent, including any bid or offer quotation, market order, limit order, or other priced order.” Note that neither indications of interest (“IOIs”) nor requests for quotes (“RFQs”) fall within the definition of an order. See, e.g., CAT FAQs B3 and B38. A “reportable event” is defined by SEC Rule 613(j)(9) to “include, but not be limited to, the original receipt or origination, modification, cancellation, routing, and execution (in whole or in part) of an order, and receipt of a routed order.”

Messages sent through OTC Link ATS constitute “orders,” as defined above, for purposes of CAT reporting obligations to the extent such messages represent a “firm indication of a willingness to buy or sell a security.” OTC Link ATS and the OTC Link ATS broker-dealer subscribers are required to report all applicable CAT reportable events relating to such orders, both executed and unexecuted.

As set forth in Table 1 (Industry Specifications Phased Approach) of the Industry Member Technical Specifications, all OTC Link messages are reportable as orders starting in Phase 2d. Detailed reporting scenarios are available in the Phase 2d Industry Member Reporting Scenarios document.