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On March 17, 2020, the SEC issued relief that exempts the Participants from collecting or retaining certain retail customer data, including (1) individual social security numbers or individual tax payer identification numbers; (2) dates of birth and (3) account numbers.  Instead, Industry Members would be required to report an account holder’s name, address, and birth year to the CAT.

Industry Members are required to obtain and report LTIDs to CAT for Firm Designated IDs (FDID) with Reportable Events that must be reported to CAT in Phase 2c (equities) and Phase 2d (options). This applies to both existing FDIDs and new FDIDs established after the Phase 2c and 2d implementation dates. Each Industry Member must determine how to obtain the LTID for each FDID – to the extent that an LTID exists – in order to report this information to CAT.

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.

Under the CAT NMS Plan, each Industry Member must submit an initial set of Customer information for Active Accounts to the CAT in Phase 2e which is scheduled to begin in July 2022. Each Industry Member must submit to the CAT any updates, additions or other changes to the Customer information on a daily basis for all Active Accounts. In addition, on a periodic basis, each Industry Member will be required to submit to the CAT a complete set of all Customer information.

The CAT NMS Plan defines a “Customer” as (a) the account holder(s) of the account at a registered broker-dealer originating the order; and (b) any person from whom the broker-dealer is authorized to accept trading instructions for such account, if different from the account holder(s). This is the same definition as set forth in Rule 613(j)(3).

An Industry Member is required to report an LEI for a Customer that is a legal entity to the CAT if the Industry Member has an LEI for a Customer. The CAT NMS Plan does not require a Customer to obtain an LEI if it does not have one, it does not require a Customer to provide an LEI to an Industry Member; and it does not require the Industry Member to request an LEI of its Customer.

No, the Participants obtained exemptive relief from the requirement in Rule 613 for a CAT Reporter to report the Customer-ID(s) for each Customer. Instead, the CAT NMS Plan requires Industry Members to report only the Firm Designated ID for each new order submitted to the CAT, rather than the Customer-ID, and the Plan Processor would associate the specific Customers and their Customer-IDs with individual order events based on the reported Firm Designated ID.