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Prior to the implementation of full Customer and Account Reporting (July 11, 2022), if an Industry Member has not recorded the date on which the Customer entered into the specified role on the account, it may populate the roleStartDate field with a start date that is reasonably available. If no start date is reasonably available, the Industry Member may populate this field with the same value as the fdidDate.

On September 21, 2021 at 4:15 p.m. Eastern Time, Consolidated Audit Trail, LLC (CAT LLC) will host an industry webinar on CAT costs. The presentation material for the webinar is available at CAT Costs Webinar- Presentation. CAT LLC requests that persons who would like to submit questions do so in advance through the following link: [email protected]. Please submit all questions by close of business, Monday, September 20, 2021.

In Phase 2c, allocations to an average price account that is held either in the name of a specific client of the Introducing Broker or is associated in the clearing firm’s systems with a specific client of the Introducing Broker are required to be reported to CAT. The allocationType for these allocations may be marked as ‘CUS’ (Allocation to a custody account) or ‘DVP’ (Allocation to a DVP/RVP accounts). 

If a Reportable Event is priced in a non-U.S. dollar currency, CAT Reporters are required to convert such prices into U.S. dollars based on the conversion rate applicable at the time that the Reportable Event occurred and report the prices in US dollars to the CAT. Although a specific conversion methodology is not prescribed, any methodology must be applied consistently by the Industry Member. 

No. Transfers of securities during an account transfer between broker-dealers (e.g. ACATS transfers, transferring a Registered Investment Advisor (RIA) book of business from one Industry Member to another Industry Member and for a clearing firm when a correspondent firm changes to another clearing firm) are not orders, as defined by SEC Rule 613. Therefore, such account transfers are not required to be reported as Transaction activity to CAT. The same guidance would apply to a firmDesignatedID (FDID) representing a Relationship ID or Entity ID. Also, see FAQ Q53.

No, only CAT Reporters that are ATSs are required to submit NBBO information to the CAT. Specifically, ATSs would be required to report certain NBBO information upon the receipt and execution of an order. 

No, neither IOIs nor RFQs are reportable to CAT, as neither falls within the definition of an "order" as set forth in the CAT NMS Plan. For CAT purposes, an IOI is a non-firm expression of trading interest that contains one or more of the following elements: security name, side, size, capacity and/or price.