Periodic Customer Account refreshes were not required in the LTID Phase but are required in the Full CAIS Phase. Note, FDIDs that are accepted in daily submissions will have met the refresh requirement. 

In light of the proposed amendment to the CAT NMS Plan regarding CAIS reporting requirements (see Securities Exchange Act Rel. No. 102665) (https://www.govinfo.gov/content/pkg/FR-2025-03-19/pdf/2025-04516.pdf), compliance with the Periodic Customer & Account Information Refresh has been delayed to a future to-be-determined date.

To provide time for testing ahead of the first Periodic Customer & Account Information Refresh Due Date, the first FDID Refresh Reports were delivered in the Test Environment on December 4, 2024 and will continue to be delivered on the third CAT Trading Day of each following month.

Additionally, the first FDID Refresh Reports were delivered in the Production Environment on January 6, 2025 and will continue to be delivered on the third CAT Trading Day of each following month. The refresh deadline will be reset for FDID Records that are refreshed in the Production Environment. The FDID Refresh Reports are being delivered in the Production Environment for testing purposes and unrefreshed FDIDs may display a Refresh Due Date in the past and a Status of OVERDUE. Since these FDID Refresh Reports are being delivered ahead of compliance with the first Periodic Customer & Account Information Refresh requirement (which, as noted above, has been delayed to a future to-be-determined date), these FDIDs are not subject to the compliance requirement until further notice. 

See the Periodic Customer & Account Information Refresh section of the CAT Reporting Customer and Account Technical Specifications for Industry Members-Full CAIS for more information.