How do the CAT reporting requirements for Large Trader IDs (LTIDs) and Legal Entity Identifiers (LEIs) differ?
As explained in FAQs Q6 and Q31, CAT Reporters are required to obtain and report LTIDs to CAT, including introducing brokers and executing brokers that use separate clearing brokers. In contrast, Legal Entity Identifiers (LEIs) are not required to be disclosed to a broker-dealer, nor is a broker-dealer required to obtain an LEI from its customers. Further, there are no obligations imposed by SEC Rule 613 or the CAT NMS Plan to obtain an LEI from a customer for purposes of reporting it to CAT. Therefore, LEIs are only required to be reported to CAT if the CAT Reporter has otherwise obtained an LEI for a particular customer.