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M. Firm Designated ID
This topic includes information related to the Firm Designated ID (“FDID”) and use cases.
On Wednesday, August 12, 2020 at 2 pm ET, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host an industry webinar focusing on LTID submission ahead of the LTID Information Testing Environment opening on August 24, 2020.
Please note that FINRA CAT, LLC is now utilizing Zoom to conduct industry webinars. Please check your firewall to ensure your firm has the ability to view Zoom content. If you are unable to download and run Zoom, please click the "join from your browser" link. The presentation document and recording will be posted.Audio file
Before the reporting of Customer Account Information and Customer Identifying Information begins in July 2022 regulatory users of the CAT will use FDIDs to identify whether the same account is trading within a single broker-dealer. After the reporting of Customer Account Information and Customer Identifying Information begins, FDIDs will be used to link accounts to specific customers, including mapping accounts with common ownership (for instance, where a customer is associated with more than one FDID).
Industry Members (other than Small Industry Members) and Small Industry Members that are required to record and report information to FINRA’s Order Audit Trail System pursuant to applicable SRO rules (“Small Industry OATS Reporters”) must report FDIDs for the original receipt or origination of an order that is required to be reported in Phase 2a to the CAT beginning on June 22, 2020. Small Industry Members that are not OATS Reporters must report the FDID when they begin submitting data to CAT on December 13, 2021.
- FAQM15. What should be reported as the Firm Designated ID (“FDID”) when an employee of the Industry Member is exercising discretion over multiple client accounts and creates an aggregated order for which a trading account number of the Industry Member is not available at the time of order origination?
When an employee of the Industry Member is exercising discretion over multiple client accounts and creates an aggregated order for which a trading account number of the Industry Member is not available at the time of order origination, the FDID can be populated by the Entity ID instead of the identifier for an account number. An Entity ID is an identifier of the Industry Member that represents the firm discretionary relationship with the client rather than a firm trading account.
On Wednesday, February 19, 2020, at 4:15 pm ET, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host an Industry Webinar, FDID Refresher and Introduction to Allocation Reporting. This Webinar will include a refresher on the Firm Designated ID (FDID) requirements for Phases 2a and 2b and an introduction to Allocation reporting for Phase 2c.Audio file
- FAQM14. If an Industry Member does not have an account number available to its order handling and/or execution system at the time of order receipt, what should be reported as the Firm Designated ID (FDID)?
In certain scenarios (e.g., institutional, managed accounts), the trading account structure may not be available when a new order is first received from a client and instead, only an identifier representing the client’s trading relationship is available. In these limited instances, the Industry Member may populate the FDID with an identifier used by the firm to represent the client’s trading relationship with the Industry Member (“Relationship ID”) instead of an account number.
An example of such an identifier could be as follows:
On Wednesday, January 8, 2020, at 2 pm ET, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host a CAT 101 Industry Webinar. This Webinar is designed for Industry Members that may be new to, or less familiar with, CAT and will provide an introduction to the reporting requirements, timelines and mechanics of the Consolidated Audit Trail. The event will be held at 2 pm ET.Audio file
- EventIndustry Webinar – Initial CAT Reporting Customer and Account Technical Specifications for Industry Members-LTID (12/18/2019)
On Wednesday, December 18, 2019, at 4:15 pm ET, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host an Industry Webinar. This Webinar will cover the FDID and LTID reporting requirements included in the Initial CAT Reporting Customer and Account Technical Specifications for Industry Members- LTID . The event will be held at 4:15 pm ET.Audio file