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No, the firmDesignatedID submitted to CAIS must be the same firmDesignatedID populated on the related Transaction Order event for a specific trading account, Relationship ID or Entity ID. 

​On Tuesday, May 18, 2021 at 9 am ET, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host an industry webinar to highlight the customer and account reporting requirements of the CAT NMS Plan and give an overview of the CAT Reporting Customer and Account Technical Specifications for Industry Members-CCID v2.0 r2.

On Wednesday, May 5, 2021 at 4:15 pm ET, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host an industry webinar to review the requirements for translating Input Identifiers of CAT Customers to Transformed Identifier Values. All Industry Members are required to report Transformed Identifier Values for CAT Customers to the Customer and Account Information System (CAIS) beginning in July 2022. This webinar will also provide an overview of the paired files submission process for the CAIS Data file and Transformed Identifiers file.

Firm Designated ID (FDID) is defined in Section 1.1 of the CAT NMS Plan as “a unique identifier for each trading account designated by Industry Members for purposes of providing data to the Central Repository, where each such identifier is unique among all identifiers from any given Industry Member for each business date.”

Yes. CAT allows multiple vendors to submit data on behalf of a single Industry Member CAT Reporter. Each vendor reporting Transaction Order events requiring a Firm Designated ID (FDID) on behalf of an Industry Member CAT Reporter would have to provide the same FDID as required. A single FDID assigned to each trading account must be unique, persistent and consistent within the firm and across all vendors, and unique across time.

No. The Plan Participants are not prescribing any specific methodology that must be used to mask or otherwise transform account numbers for the purposes of reporting the Firm Designated ID (FDID) to CAT. Each Industry Member must, however, ensure the methodology used to mask or otherwise transform an account number does not result in a newly created unique identifier or an internal only identifier that can be used to effect a transaction or would not constitute "Customer Account Information" as defined in the CAT NMS Plan.

The account or entity identifier used to place the order must be reported. In scenarios where a master/top account or entity identifier is used to place an order, the Firm Designated ID (FDID) representing the master/top account or entity identifier should be reported to CAT for Transaction Order events requiring an FDID (e.g. New Order and Trade events). In such scenarios, the FDID represents the master/top account or entity that is authorized to place orders for one or more legal entities or customers.

As stated in FAQ M1, a change in the FDID associated with a particular trading account would only be permissible in certain limited circumstances, such as closed accounts, system migration, and change of vendors. 

If an Industry Member has reported an FDID on a Transaction Order event (e.g., MENO, MEOF, MEOT) and subsequently changed the FDID associated to that particular trading account prior to the implementation of full Customer and Account Reporting on July 11, 2022, then the Industry Member has additional obligations as outlined below. 

All Industry Members

No. Unless a new account or entity identifier is assigned to a client or customer, each Firm Designated ID (FDID) must be unique, persistent and consistent for each trading account within the firm and across all vendors and systems the Industry Member may use to report Transaction Order events requiring an FDID to CAT and associated Customer and Account information for the FDID to CAT CAIS, and unique across time (with limited exceptions, such as closed accounts, system migration, and change of vendors). For more information on these limited exceptions and changing an FDID, see FAQ M16.

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 commence reporting Firm Designated IDs (FDID) on all Transaction Order events requiring an FDID to the CAT in Phase 2a beginning on June 22, 2020. Small Industry Members that are not Small Industry OATS Reporters must commence reporting FDIDs on all Transaction Order events requiring an FDID to the CAT by December 13, 2021.