As described in the CAT Industry Member Technical Specification (“Tech Spec”) document certain events that occur within systems used by Floor Brokers on the NYSE’s equities or options floors are required to be reported to CAT pursuant to SEC Rule 613(c)(7). Generally, Floor Brokers on both the equities and options trading floors receive orders from one of several sources and such orders are processed via an order management system (“OMS”) before they are entered into an exchange for execution. For example, Floor Brokers may receive an order from within their own firm, which has electronically routed the order from one of its internal systems into the Floor Broker’s OMS. For CAT reporting purposes, that transfer of an order from the firm’s own internal system to that firm’s Floor Broker OMS on the floor of the NYSE is likely CAT reportable as an intrafirm transfer/internal route as described in the Tech Specs and required by Rule 613(c)(7)(ii)(F) and Rule 613(c)(7)(iii). In another scenario, Floor Brokers may receive an order from an outside source and enter it into the firm’s Floor Broker OMS. In this scenario, the Floor Broker must record and report the time of the order receipt as described in SEC Rule 613(c)(7)(i)(E), Appendix C at section A(1)(a)(iii) of the CAT NMS Plan and also described in the Tech Specs.

After a Floor Broker receives the order and the order is in the Floor Broker’s OMS, the Floor Broker determines how to represent their order. A Floor Broker may, for example: 1) send the order back to the source if routed directly to the Floor Broker’s OMS by another desk within the Floor Broker’s firm; 2) electronically send the order directly to an exchange system for execution; 3) electronically route the order to a third-party provider that determines where to route the order (to an exchange or other execution venue); or 4) orally represent and then execute the order on the floor. Each of these scenarios may include events that trigger an obligation to report to CAT.

In the first three scenarios, electronically routing an order from the Floor Broker’s OMS to another of the Floor Broker firm’s internal systems, to an exchange, or to a third-party provider constitutes a CAT-reportable event pursuant to Rule 613(c)(7)(ii). For the fourth scenario, if the Floor Broker orally represents an order on the trading floor, no reportable events are occurring until an execution is reported. The execution triggers a CAT-reporting obligation for the Floor Broker, who is responsible for reporting the time of order execution pursuant to SEC Rule 613(c)(7)(v) and as described in the Tech Spec. The time of execution as required by Rule 613(c)(7)(v)(C) is the time at which the Trading Official (options floors) releases the order to the Floor Broker for reporting to the exchange, or is the time at which the DMM (equities floor) reports the matched trade to the exchange. The Floor Broker is responsible for reporting each CAT-reportable event required by Rule 613, although a Floor Broker may arrange for the exchange to report on the Floor Broker’s behalf. The Floor Broker should contact NYSE Member Services to ensure reporting by the industry member reporting deadlines.