Q. Customer and Account Information
This topic includes information related to the requirements for reporting customer and account data to the CAT.
On Wednesday, October 13, 2021 at 4:15 pm ET, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host an industry webinar focused on the transition from LTID to Full CAIS reporting as it relates to schema changes, timing and other related issues.Audio file
Consolidated Audit Trail, LLC and FINRA CAT, LLC will host a Monthly CAT Implementation Update on the third Thursday of every month at 4:15 pm ET. The Monthly CAT Implementation Update meetings provide the industry with a high level overview of materials and guidance published on the www.catnmsplan.com website during the month.
Consolidated Audit Trail, LLC and FINRA CAT, LLC will host a monthly Industry Testing Checkpoint Call for CAIS/LTID on Wednesday, November 3, 2021 at 4:15 pm ET.
Please note that FINRA CAT, LLC utilizes 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. This webinar will be recorded. The presentation document and recording will be posted.
- Reference Material
- EventAudio file
- FAQQ53. FAQ B53 states that account transfers between broker-dealers are not orders, as defined by Rule 613. How should such activity be reflected in CAIS?
As stated in FAQ B53, transfers of securities during an account transfer between broker-dealers (e.g., ACATS transfers, transferring a Registered Investment Advisor (RIA) book of business from one Industry Member to another Industry Member and for a clearing firm when a correspondent firm changes to another clearing firm) are not orders, as defined by SEC Rule 613. Such account transfer activity as outlined above between Industry Members does not meet the definition of Mass Transfer of FDIDs across CAT Reporter Firms for CAT CAIS reporting requirements.
- FAQQ52. What date should Industry Members use to populate the “end date” fields (e.g., fdidEndDate, roleEndDate) when an event has triggered the closure of an account? For example, when a minor reaches the age of majority for a custodial account (e.g., UGMA/UTMA) or upon the death of an account holder for a beneficiary account, how should Industry Members populate these fields?
If the Industry Member’s practice is to close an account and open a new account in the scenario where there is a triggering event, the Industry Member must populate the “end date” fields with the date that is maintained in its books and records.
The updated record is required to be reported to CAT CAIS by 8:00 a.m. Eastern Time on the CAT Trading Day following the day the Industry Member confirmed the date in its books and records.
- FAQQ51. How should an Industry Member populate the roleStartDate field if it did not record the date on which the Customer entered into the specified role on the account?
Prior to the implementation of full Customer and Account Reporting (July 11, 2022), if an Industry Member has not recorded the date on which the Customer entered into the specified role on the account, it may populate the roleStartDate field with a start date that is reasonably available. If no start date is reasonably available, the Industry Member may populate this field with the same value as the fdidDate.
- EventAudio file
For the month of September 2021, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host the Monthly CAT Implementation Update on the second Thursday, September 9, 2021, at 4:15 pm ET. The Monthly CAT Implementation Update meetings provide the industry with a high level overview of materials and guidance published on the www.catnmsplan.com website during the month.Audio file