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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.

If an LTID to FDID association is ended erroneously and must be reestablished, the Industry Member should populate the ltidEffectiveDate with the original LTID Effective Date- not the date that the record reestablishing the association is submitted to CAT CAIS. 

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. 

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.

Industry Members may resubmit the same record each business day but are not required to. If an Industry Member resubmits an identical record to one that already exists in CAT CAIS, CAT CAIS will overwrite the previous record with the new record with the same information. Once a record has been received by CAT CAIS, Industry Members are only required to submit changes or corrections to required data elements. 

The ltidEffectiveDate in this scenario is the date the Industry Member was provided the LTID and it was associated with the account.

If an LTID to FDID association is ended for a legitimate reason and must be reestablished, the Industry Member should populate the ltidEffectiveDate with the date on which the LTID or ULTID became re-associated to the FDID within the CAT Reporter’s system- not the original LTID Effective Date. 

As described in the Customer and Account (LTID) Technical Specifications, in the scenario a CAT Reporter that is a clearing firm or self-clearing firm determines a person (which includes both natural persons and legal entities under Section 13(h)(8)(E) of the Exchange Act) would qualify as a large trader, but the firm has not yet been provided with an LTID by the person, the clearing firm or self-clearing firm is required to assign an ULTID to the person until such time as the person provides their LTID.