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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.

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:

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 in April 2020. Small Industry Members that are not OATS Reporters must report the FDID when they begin submitting data to CAT in December 2021.
 

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. 

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.

Additional information regarding the FDID may be found here and here.