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Consolidated Audit Trail, LLC and FINRA CAT, LLC 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.

Concurrent with Phase 2c (April 26, 2021), LTIDs or ULTIDs associated with FDIDs must be reported in the LTID phase of CAIS (“CAIS LTID”) when all three of the following conditions are met:

• a.    The Industry Member is a Large Industry Member (which is an Industry Member other than a Small Industry Member); AND

• b.    The FDID has an associated LTID or ULTID; AND

• c.    The FDID is reported in equities and/or options events to CAT on or after April 26, 2021. CAT Reportable Events requiring an FDID include:

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.

Consolidated Audit Trail, LLC and FINRA CAT, LLC will host a monthly Industry Testing Checkpoint Call for CAIS/LTID on Wednesday, April 7, 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.

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. 

In this case where there are multiple dates associated with an account prior to the CAT CAIS Implementation date (July 11, 2022), CAT Reporters should report the account open date that is reasonably available. (See CAT NMS Plan, Article 1, Section 1.1 definition of “Account Effective Date”). For example, if a CAT Reporter has physical account papers located in an offsite storage system and a systematized date, both of which were opened prior to the CAT CAIS Implementation date, it is reasonable to use the systematized account effective date.

The ltidEffectiveDate in this scenario is the date the Industry Member was provided the LTID and it was associated with the account. If an Industry Member stores LTIDs at the entity, top account or relationship level (for example, in the case of institutional accounts), the ltidEffectiveDate may be reported as the date the Industry Member associated the LTID to the top-level account (for all associated subaccounts) or the entity or relationship level for all associated FDIDs.