- FAQU9. What value should be used to populate the eventTimestamp in the Post-Trade Allocation event (MEPA) or Option Post-Trade Allocation event (MOPA)?
The eventTimestamp on an Allocation event should reflect the date and time in which the shares or contracts allocated are booked into the customer or client’s account. For firms that have multiple “booking times” that are captured in their backend system, this is the booking time that reflects the placement of shares or contracts into the customer account.
- FAQU14. When may the Amended Allocation/Option Amended Allocation (MEAA/MOAA) events be reported to CAT?
If an allocation is updated such that a CAT reportable attribute is changed after the shares/contracts have been booked in a customer or client account, then an Amended Allocation event (MEAA) or Option Amended Allocation Event (MOAA) may be reported to CAT reflecting the corrected details of the allocation.
- FAQU8. Are allocations to a registered investment advisor (RIA)/money manager’s average price account required to be reported even if the shares are only held there temporarily before being allocated to individual customer accounts? For example, an RIA manages two customer accounts at a self-clearing firm. The RIA places a single order in its account that will be later allocated between the two customer accounts. The shares are booked to an average price account designated for the RIA at the self-clearing firm until the RIA provides subaccount allocation instructions and the allocations are made to the individual customer accounts.
Yes, all allocations to customer accounts are required to be reported even if the shares are only held there temporarily. In this scenario, the self-clearing firm would have to report the allocation to the RIA’s average price account as well as the subaccount allocations to the individual customer accounts.
- FAQU16. Are accounts maintained by a clearing firm that are owned or controlled by another broker-dealer considered “customer” accounts for purposes of reporting Allocation Reports to CAT? For example, shares are booked into the average price account of an Introducing Broker (IB) dealer before the IB provides allocation instructions to the final customer accounts. Is the booking of shares into the IB owned or controlled average price account required to be reported as an Allocation by the clearing firm to CAT?
No, allocations to any account owned or controlled by a broker-dealer are not required to be reported to CAT as Post-Trade Allocation (MEPA) or Option Post-Trade Allocation (MOPA) events. Allocations to an account owned or controlled by a broker-dealer may be voluntarily reported to CAT but must be properly identified as such using the correct allowable value in the allocationType field. Note that average price accounts designated exclusively for a specific customer (not a broker-dealer) are always considered customer accounts.
No. CMTAs are not allocations, as defined by SEC Rule 613. Therefore, CMTAs are not required to be reported to CAT. However, CMTAs may optionally be reported to CAT in the Option Post-Trade Allocation (MOPA) and Option Amended Allocation (MOOA) events using the allocationType value of ‘CMTA’ and populating the occClearingMemberID field.
- FAQU30. FAQ U29 states that in Phase 2d, the TIDType on the allocation events may optionally be populated with the Input Identifier used for the account holders associated with the FDID record in CAIS. How should the TIDType field be populated if there are multiple account holders associated with an FDID record and the CAT Customer records were generated using different Input Identifiers?
In Phase 2d, the TIDType field is optional but may be required at a future date no sooner than July 11, 2022. If optionally populated in Phase 2d, only a single allowable value is permitted in the TIDType field on allocation events. If there are multiple underlying account holders associated with the FDID record in CAIS, and the CAT Customer records were generated using various Input Identifiers (i.e., SSN, EIN, and FOR), the Industry Member must choose a single allowable value that represents an account holder.
- FAQU29. The TIDType on the allocation events must be populated with the Input Identifier used for the account holders associated with the FDID record in CAIS. If account holders and authorized traders are associated with an FDID record, which type of CAT Customer should be represented by the TIDType in allocation events?
In Phase 2d, the TIDType field is optional but may be required at a future date no sooner than July 11, 2022. The TIDType field on the allocation events (MEPA/MEAA and MOPA/MOAA) must be populated with the Input Identifier used for the account holder(s) associated with the FDID record in CAIS. If optionally reported, the TIDType field must not represent an individual or entity that is an authorized trader who is not an account holder.
- FAQU1. The newOrderFDID field in the Post-Trade Allocation/Option Post-Trade Allocation Event (MEPA/MOPA) and Amended Allocation/Option Amended Allocation Event (MEAA/MOAA) is described as “The FDID of the related New Order event, if available in the booking system.” What does “if available in the booking system” mean?
Starting in Phases 2c (for equities) and 2d (for options), “if available in the booking system” means that the FDID is either directly available in the booking system, or can be made available through a simple reference data lookup, or can be readily accessed by the booking system through an existing system integration. For example, if the FDID is directly stored or can be directly queried by the booking system, the newOrderFDID field should be populated.
- FAQU17. Are changes to CAT reportable attributes of an allocation after the original booking of shares/contracts that occur post-settlement required to be reported to CAT as an Amended Allocation/Option Amended Allocation (MEAA/MOAA) event?
Changes to CAT reportable attributes of an allocation after the original booking of shares/contracts are required to be reported to CAT as either an Amended Allocation/Option Amended Allocation (MEAA/MOAA) event or the cancellation of a Post-Trade Allocation/Option Post-Trade Allocation (MEPA/MOPA) event followed by a new Post-Trade Allocation/Option Post-Trade Allocation event regardless if they occur pre-settlement or post-settlement.
- FAQU18. Are Industry Members required to report Amended Allocation/Option Amended Allocation events (MEAA/MOAA) for allocations which occurred before the date an Industry Member is required to report allocation events to CAT?
If the trade date of the allocation is prior to the mandatory reporting date for allocations (Phase 2c for equities and Phase 2d for options), then any amendments made to the allocation after the applicable CAT allocations reporting go-live date are not required to be reported to CAT.