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The CAT NMS Plan requires Industry Members to “submit to the Central Repository” information  “including CRD number and LEI, if such LEI has been obtained.” “Central Repository” means the repository responsible for the receipt, consolidation, and retention of all information reported to the CAT pursuant to SEC Rule 613 and this Agreement. 
 
The CAT NMS Plan requirement does not require Industry Members to obtain an LEI, but rather to provide its LEI to the Plan Processor (FINRA CAT) if the Industry Member does have an LEI. 

CAT Alert 2020-04 outlines the standards for self reporting erroneous event to FINRA CAT. This alert provides information about self-reporting, including who may self-report, when to self-report, the considerations for when to self-report, and how to complete and submit the Self-Reporting Erroneous Events Form.

2020 Entitlement Certification Period for CAT Reporting Agents (Not Applicable to Industry Members). FINRA CAT will launch an online Entitlement Certification Process for CAT Reporting Agents on October 13, 2020, which requires each organization to review and verify all CAT accounts (user, administrator, machine) by December 17, 2020.  In order to certify accounts, each CRA must designate a Certification Representative (CRep) by September 25, 2020. 

No, order events occurring prior to an IPO symbol’s inclusion on the CAT Reportable Securities List are not required to be reported to CAT in Phase 2a. In Phase 2a, secondary events that occur after an IPO symbol’s inclusion on the CAT Reportable Securities List that are reported to CAT and are marked unlinked for parent not found will not be considered a CAT Reporting violation if at the time of the parent event, the symbol was not on the CAT Reportable Securities List.