FAQs

A representative order is defined as an order originated by an Industry Member for the purpose of working one or more orders. Representative orders may be originated in firm owned or controlled accounts or a customer or client account.  

Examples of representative orders in firm owned or controlled accounts:

1. Order originated in a proprietary account to work an order on a riskless principal basis.
2. Order originated in a proprietary account to work an order on a net basis.
3. Order originated in a proprietary account to work one or more proprietary orders.
4. Order originated in a firm owned agency average price account to work an order(s) on an average price basis.
5. Order originated in a firm owned omnibus or agency average price account to aggregate and work multiple customer or client orders as a single order.

Example of a representative order in a customer or client account:

Order originated in a customer or client account or for a single Relationship ID to aggregate and work multiple orders from the same customer or client as a single order. In these instances, the Industry Member must report representative orders with representativeInd value of ‘Y’. Also, the resulting fulfillment events must be reported with fulfillmentLinkType value of ‘Y’.

See Appendix C of the Industry Member Technical Specification and Section 2.3 of the CAT Industry Member Reporting Scenarios document for detailed guidance and examples of how the representative orders must be reported.

No. The CAT Order Fulfillment report is not required to be linked to any related non-media riskless principal regulatory report. Because the street side order and any related media reported trades are linked to the related customer orders in CAT (subject to the phased implementation schedule), linkage of the CAT Order Fulfillment Report to the related non-media TRF report is not required. 

If an Industry Member’s order handling and/or reporting system does not allow for a route to be directly associated with the customer order or child order (with the same Order ID) and instead must generate/report a route from a separate order (with a different Order ID) created by the Industry Member for the purpose of working the customer order, then an Order Fulfillment should be used as described in Scenario 2.3.4 Fill of a Single Customer Order on an Average Price Basis in the CAT Industry Member Reporting Scenarios document.

More simply put, if an Industry Member is able to report the route directly linked to the customer order, the Industry Member should report Order Route events in accordance with Scenario 2.1.6. If the Industry Member is unable to report Order Route events, the Industry Member must report a representative order in accordance with Scenario 2.3.4.
 

In this scenario, the Industry Member must report four New Order Events to reflect the receipt of each customer order and an individual Order Fulfillment Event to show the fill of each customer order. Additionally, the Industry Member must report a New Order Event to reflect the aggregated representative order and any related Route Events. In Phase 2c, the street side representative order must be linked to the individual customer orders.

Yes, Industry Members are required to link a Representative Order with the underlying order(s) that it represents. Specifically, Industry Members are required to record and report to the Central Repository: (1) for original receipt or origination of a Representative Order, the CAT-Order-ID(s) and quantities of the underlying order(s), and whether linkage to the underlying order(s) is required, and (2) if the Representative Order is modified or cancelled, the CAT-Order-ID(s) and quantities of the underlying order(s). While all Representative Orders must be reported beginning in Phase 2a, the linkage requirements to the underlying orders will be phased in as described in the Industry Member Technical Specifications. 

All Industry Members will be required to provide representative order linkages to unlinked OMS/EMS and position fill scenarios no later than January 31, 2026 due to the expiry of the exemptive relief granted by the SEC on July 23, 2025.

As stated in FAQ F5, Industry Members are required to link a Representative Order with the underlying order(s) that it represents. There are limited instances where linkage is required at the client fill level rather than the order level using the Firm Designated ID (“FDID”) of the firm owned or controlled account from which the customer order was filled. Specifically, for orders that are originated in different systems that are not linked in an Industry Member’s systems, such as a customer order originated in an Order Management System (“OMS”) and represented by a principal order originated in an Execution Management System (“EMS”) that is not linked to the OMS, Industry Members are required to link the fill of the customer order to the FDID of the firm owned or controlled account that was used to originate and execute the Representative Order. Further, such Representative Orders must be reported to CAT with an indicator reflecting the order is eligible for customer fills from an unlinked system. Appendix C of the Industry Member Technical Specifications provides details of the required linkages in these workflows. 

All Industry Members will be required to provide representative order linkages to unlinked OMS/EMS and position fill scenarios no later than January 31, 2026 due to the expiry of the exemptive relief granted by the SEC on July 23, 2025. 

The only Representative Order workflow in which linkage is not required at either the order level or the fill level is that in which a firm receives a client order, guarantees an execution price (e.g., GVWAP) and then originates proprietary orders in an effort to work the client order. Because the client order may not ultimately be filled from the proprietary order(s) if the guaranteed price is not achieved, direct linkage is not required. Although direct linkage is not required to the client fill, the proprietary orders originated to work the client order must be marked as a Representative Order and designated as part of a price guarantee scenario. Appendix C of the Industry Member Technical Specifications provides the specific reporting requirements for price guarantee scenarios.
 

In representative order scenarios, the representativeInd field in a New Order event indicates the type of representative order being reported, and whether order level linkage is required. Order level linkage is specified through the aggregatedOrders field of the representative order’s New Order event, which identifies each related customer New Order event that is being represented. Fulfillment level linkage is identified through the fulfillmentLinkType field, which indicates the type of fulfillment and whether linkage is required. Fulfillment level linkage is specified through the firmDetails field in an Order Fulfillment event, and identifies the related representative order from which the fill was obtained.

Order level linkage does not determine fulfillment level linkage. A representative order may have order level linkage without fulfillment level linkage (e.g., unexecuted order), and may have fulfillment level linkage without order level linkage (e.g., a customer order filled from a pre-existing principal order such as a Manning execution, or in the case of a disconnected OMS/EMS). A representative order may also have both order and fulfillment level linkage with different values populated in the representativeInd and fulfillmentLinkType fields (e.g., the firm order originated to represent the order was not the order that was ultimately used to fill the customer order). Refer to Appendix C of the IM Technical Specifications for additional information.

All Industry Members will be required to provide representative order linkages to unlinked OMS/EMS and position fill scenarios no later than January 31, 2026 due to the expiry of the exemptive relief granted by the SEC on July 23, 2025.