In the scenario where an Industry Member has systematized all data required to report a Natural Person Authorized Trader, it must report all information required for a complete Customer Record, including tidValue and yearOfBirth. However, in the scenario where an Industry Member has not historically collected and systematized all data required to report a Natural Person Authorized Trader and will not be able to collect and systematize the data by the Full CAIS Compliance Go-Live date per the implementation schedule as set forth in CAT Alerts – 2022-01 and 2023-01, the Plan Participants will have temporarily made available an Authorized Trader Names List on the FDID Record.
The Authorized Trader Names List will enable the Industry Member to report only the name of the Natural Person Authorized Trader having authority to trade on the Account, where they do not have all data required to report the Authorized Trader as a Natural Person CAT Customer. Each FDID submitted must still have at least one active association to a CAT Customer reported with a TID and all required data, with trading capabilities.
Use of the Authorized Trader Names List is only allowable on a temporary basis and, with sufficient time and notice, will be retired from the Full CAIS Technical Specifications at a future date. Thus, Industry Members will be required to resubmit the FDID Record to CAIS with all required data for a full CAT Customer Record.
While the Plan Participants are providing this temporary technical solution to allow an Industry Member to report an incomplete Customer Record for a Natural Person Authorized Trader to CAIS effective with the implementation of full Customer and Account Reporting (in lieu of having that Customer Record rejected), use of the Authorized Trader Names List is not in compliance with the Plan. There currently is no exemptive relief that would allow only the submission of an incomplete Customer Record for a Natural Person Authorized Trader. Use of the Authorized Trader Names List rather than the submission of all information required for Natural Person Authorized Traders could be subject to review by Regulators. Accordingly, Industry Members are encouraged to report all data required for Natural Person Authorized Traders as soon as possible before the Full CAIS Compliance Go-Live date.
The requirement to report to CAT CAIS a firstName, lastName, yearOfBirth, tidType and tidValue (i.e., a hashed version of an Input Identifier, such as a social security number) for all Natural Person Authorized Traders means that CAT may impose new recording and reporting obligations on some Industry Members with respect to obtaining Customer information to meet their CAT reporting obligations. Some Industry Members may have to change current onboarding activities to ensure Customer information is obtained and recorded for any Active Accounts with CAT Reportable Events, including for accounts that existed prior to the effective date of the CAT NMS Plan.