All accounts, Relationships or Entity IDs (as represented by the FDID/Firm Designated ID) with any CAT-reportable activity (equities, options and/or multileg events) on or after June 12, 2022 must be reported to CAIS with the implementation of Phase 2e (Full CAIS). See CAT Alerts 2022-01 and 2023-01 for the Full CAIS Implementation Schedule.
Example 1 (FDID in scope for Full CAIS reporting)
On June 22, 2020 (the Phase 2a Go-Live date), FRMA had an obligation to report a New Order event (MENO). The order remained open until August 17, 2022, when it was cancelled. Because the FDID had CAT-reportable activity after June 12, 2022, FRMA has a CAIS reporting obligation for this FDID. By contrast, if the open order did not have any subsequent CAT-reportable activity as of the date that FRMA was required to report this FDID to Full CAIS, FRMA would not have a CAIS reporting obligation for this FDID at that time.
Example 2 (FDID in scope for Full CAIS reporting)
FRMB received a customer order on June 12, 2022 and reported a MENO. The account was permanently closed off FRMB’s books on July 1, 2022. FRMB has a CAIS reporting obligation for this FDID because it had CAT-reportable activity on June 12, 2022. When FRMB is required to report this FDID to Full CAIS, it must submit this FDID Record with an fdidEndReason of ‘ENDED’ and fdidEndDate of July 1, 2022.
Example 3 (FDID NOT in scope for Full CAIS reporting)
FRMC is a clearing firm with an obligation to report post-trade allocation events (MEPA/MEAA/MOPA/MOAA). On June 22, 2021, FRMC allocated shares to FDID1234. As of June 12, 2022, there has been no further CAT-reportable activity for this FDID. Since there has been no CAT-reportable activity related to the FDID on or after June 12, 2022, FRMC does not have a CAIS reporting obligation for this FDID. However, should FDID1234 subsequently have any CAT-reportable activity, it will be in scope for Full CAIS reporting.
Example 4 (Business Model with no Full CAIS reporting obligation)
FRMD only accepts orders from other CAT Reporters and immediately routes them away for execution. Since FRMD only reports order accepted events (MEOA/MOOA/MLOA) and order route events (MEOR/MOOR/MLOR) which do not have the firmDesignatedID field on them, FRMD does not have a CAIS reporting obligation for this business model. However, if FRMD has firm-owned/controlled accounts (such as an error account) with activity on or after June 12, 2022, FRMD would have a CAIS reporting obligation for those firm-owned/controlled accounts.