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Q. Customer and Account Information
This topic includes information related to the requirements for reporting customer and account data to the CAT.
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
Periodic full account refreshes will be required beginning in Phase 2e (full CAIS July 2022).
- FAQQ18. When are account movements between broker-dealers (e.g., merger/acquisition) required to be linked in CAIS?
Account movements must be linked in CAIS beginning in Phase 2e (full CAIS July 2022).
Consolidated Audit Trail, LLC and FINRA CAT, LLC will host Weekly Industry Testing Checkpoint Calls for CAIS/LTID every Wednesday at 4:15 pm ET beginning on August 26, 2020 until further notice. The events will be held at 4:15 pm ET.
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.
On Thursday, July 9, 2020 at 11 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 DRAFT v2.0.Audio file
- FAQQ3. When must Industry Members submit Customer Account Information and Customer Identifying Information to the CAT?
The reporting of Customer Identifying Information and Customer Account Information consists of two phases, an earlier phase in which Industry Members must report to the CAT certain account information regarding account holders with a Large Trader Identification (LTID) number or an Unidentified Large Trader Identification (ULTID) number pursuant to SEC Rule 13h-1 (collectively called “LTID Account Information”), and a later phase that requires Industry Members to report all Customer Identifying Information and Customer Account Information.
- FAQQ13. How should an Industry Member populate the ltidEffectiveDate if it did not record the date on which the LTID or ULTID became associated to the FDID within its systems?
Industry Members must record in their systems the date that an LTID or ULTID becomes associated with an FDID (“LTID Effective Date”). Some Industry Members may have to change current onboarding activities to ensure this information is obtained and recorded.
If an Industry Member has not recorded the LTID Effective Date, they may use the go-live date as the ltidEffectiveDate until the go-live date. Starting on the go-live date, Industry Members must record and report an accurate LTID Effective Date.
Industry Members should make an effort to obtain an accurate reason as to why the LTID or ULTID is no longer associated to the FDID.
- FAQQ17. Are Industry Members required to report LTIDs for dormant or inactive accounts? For example, an Industry Member has a customer that qualifies as a Large Trader but that customer has not had any account activity for several months.
Industry Members are only required to report LTIDs for active accounts. That is, accounts for which there is CAT reportable activity.
The ltidEndDate is the date the Industry Member became aware that the LTID or ULTID was no longer associated with the FDID.