Concurrent with Phase 2c (April 26, 2021), LTIDs or ULTIDs associated with FDIDs must be reported in the LTID Phase of CAIS (“CAIS LTID”) when all three of the following conditions are met:
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a. The Industry Member is a Large Industry Member (which is an Industry Member other than a Small Industry Member); AND
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b. The FDID has an associated LTID or ULTID; AND
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c. The FDID is reported in equities and/or options events to CAT on or after April 26, 2021. CAT Reportable Events requiring an FDID include:
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i. New Order, Trade and Order Fulfillment events (MENO, MENOS, MONO, MONOS, MENQ, MEOT, MEOTS, MEOF)
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ii. Equity Allocation events (MEPA, MEAA)
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For an FDID reported in an equity and/or options event prior to April 26, 2021, the FDID is not required to be reported to CAIS until or unless that FDID is reported in an equity and/or options event occurring on or after April 26, 2021.
For example:
A Large Industry Member has recorded FDID XYZ456 which has an associated LTID. On February 2, 2021, the Industry Member accepts a GTC order for FDID XYZ456. On April 26, 2021, FDID XYZ456 has no reportable activity even though the GTC order remains active. At 8:30 am ET on April 29, 2021, the GTC order for FDID XYZ456 is executed and reported on an MEOT. The Industry Member now has a CAIS reporting obligation and is required report this FDID and associated LTID information to CAIS no later than 8 am ET on April 30, 2021. For more information on reporting deadlines in the CAIS LTID Phase see FAQ Q21.
Concurrent with Phase 2d (December 13, 2021), Large Industry Members must report any additional LTIDs or ULTIDs associated with FDIDs that have events reportable to CAT as of and including Phase 2d using the same conditions as above, with the addition of Option Allocation events (MOPA, MOAA).
In addition, Small Industry members must report LTIDs or ULTIDs associated with FDIDs that have events reportable to CAT as of and including Phase 2d using the same conditions as above, with the addition of Option Allocation events (MOPA, MOAA) by December 13, 2021.
NOTE: All firms satisfying the above criteria, including introducing and non-self clearing executing brokers, are required to begin reporting in the CAIS LTID Phase.
For more guidance regarding an LTID or ULTID being associated with an account, contact the SEC or see the SEC’s Large Trader Rule FAQs at https://www.sec.gov/divisions/marketreg/large-trader-faqs.htm.