CAT Transaction and CAT CAIS Production and Prod-Mirror Test Environments will be unavailable from 8 pm ET on May 14, 2021 through 2 pm ET on May 16, 2021 due to enhanced disaster recovery testing.
- FAQU25. Does an Industry Member have to report to the CAT allocations processed prior to the date an Industry Member is required to begin reporting allocation data to the CAT?
Allocation events for shares/contracts initially booked to an account or changes to shares/contracts that were initially booked to an account prior to April 26, 2021 (Phase 2c - Equities) or December 13, 2021 (Phase 2d – Options) are not required to be reported to the CAT. This includes any actions subsequent to the initial booking, such as allocation amendments or cancel/rebills.
- FAQU27. How should Industry Members populate the settlementDate field for allocations in “when-issued” securities?
Allocations in “when-issued” securities do not have a settlement date, as the settlement occurs once the symbol starts trading “regular-way”. In Phase 2c, the settlementDate field may be populated with any future date (e.g. 12/31/2099) in order for CAT to accept the record as settlementDate is a required field. From May 10, 2021, onwards, the settlementDate field will be made conditional and will not be required for “when-issued” securities.
- FAQU26. Are Industry Members that are a clearing firm required to report the booking of shares into a customer account that result from an options exercise or other non-CAT reportable transaction to CAT?
No. As noted in FAQ K4, options assignments and exercises are not orders, as defined by SEC Rule 613, and therefore are not required to be reported to CAT. Therefore, Industry Members are also not required to report the resulting booking of shares into a customer account resulting from an options assignment or exercise.
- FAQU19. How should the DVPCustodianID field in the Post-Trade Allocation event (MEPA) be populated when an allocation involves a foreign entity for which a DTC number is known?
The DVPCustodianID field in the Post-Trade Allocation event (MEPA) should accurately reflect the settlement instructions on the account (not the entity) to which shares are placed or from which shares are delivered at settlement. A Depository Trust Company (DTC) number should be reported if the account where the shares are allocated will settle the transaction via DTC.
- FAQU24. Is an Industry Member that is a clearing broker required to report an allocation report before all required information about the allocation is known? Specifically, allocations to DVP accounts require the DVPCustodianID field to be populated. How would the clearing firm report an allocation report if the DVPCustodianID is not yet available?
Because the identity of the prime broker is a required element on the allocation report to a DVP account, the allocation report cannot be reported to CAT until the DVPCustodianID is known to the clearing broker. The allocation eventTimestamp should represent the time all required elements, including the DVPCustodianID, are known to the Industry Member clearing broker.
- FAQU14. When may the Amended Allocation event (MEAA)/Option Post-Trade Amended Allocation event (MOAA) 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 client account, then an Amended Allocation event (MEAA) or Options Post-Trade Amended Allocation Event (MOAA) may be reported to CAT reflecting the corrected details of the allocation.
The term “booking” is the recording of the details related to shares/contracts owed to or delivering out of an account to the firm’s books and records. “Original Booking” is the first reasonably available time details of shares/contracts owed to or delivering out of an account are recorded to a firm’s books and records.
- FAQU16. Are accounts maintained by a clearing firm that are owned or controlled by another broker-dealer considered “client” 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 identified as a BD account as prescribed in the technical specifications. Note that average price accounts designated for exclusively for a specific customer (not a broker-dealer) are always considered customer accounts.
The CAT NMS Plan defines an Allocation Report as “a report made to the Central Repository by an Industry Member that identifies the Firm Designated ID for any account(s), including subaccount(s), to which executed shares are allocated”. This includes the booking of shares/contracts into the same account for which an order was originally placed, and the booking of shares/contracts into an account based on allocation instructions (e.g., subaccount allocations).
- FAQU21. Is the side value ‘SX’ (Short Sale Exempt) required to be reported on Post-Trade Allocation/Option Post-Trade Allocation (MEPA/MOPA) events?
If the side value ‘SX’ is available in the Industry Member’s booking system, then it should be reported on the MEPA/MOPA. If it is not available in the booking system, then the side value ‘SS’ should be reported on the MEPA/MOPA.