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Since the RIA is placing the order directly in the customer account at BD2, BD2 is required to report a New Order event (“MENO”) with a Firm Designated ID (“FDID”) that represents the customer/client account number. BD2 is also required to report any subsequent actions taken on the order (e.g., executing, routing, canceling, etc.). BD1 does not have an order in this scenario and therefore does not have a CAT reporting obligation.

Industry Members undergoing an organizational change should contact FINRA CAT, LLC to ensure that proper registrations, entitlements and reporting relationships are established in CAT, so that there are no interruptions in the Industry Member’s ability to report to CAT upon the completion of the transaction. Industry Members undergoing organizational changes should also pay particular attention to open limit orders established prior to the completion of any transaction.

The "ALL" tradingSession means that the order can trade in any available session at the venue where it is sent. For example, if an exchange only has REG tradingSession, the order may be reported with a tradingSession of “REG” or "ALL".

Most options orders are currently only eligible to trade during regular market hours sessions (generally from 9:30 am to 4:00 pm or 4:15 pm Eastern Time) on the options exchanges and, as a result, the tradingSession field must be populated with “REG” (Regular Only) or “ALL” (All Sessions).  Note that option orders eligible to trade during a regular market hours session’s opening or closing rotation must also be populated with “REG” or “ALL.”  (See also FAQ D32.) 

Consolidated Audit Trail, LLC and FINRA CAT, LLC will host Weekly Industry Testing Checkpoint Calls every Tuesday at 4:15 pm ET beginning on January 7, 2020 until further notice. The events will be held at 4:15 pm ET.

Please note that FINRA CAT, LLC is now utilizing 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. The presentation document and recording will be posted.

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.

Yes. Industry Members are required to complete production readiness testing for Phase 2a reporting by June 8, 2020.  This deadline, which was previously April 6, 2020, was extended in light of the SEC’s exemptive order, which moved the date by which Industry Members must begin reporting Phase 2a data from April 20, 2020 to June 22, 2020.

Phase 2b production readiness testing for Industry Members not submitting equities data in Phase 2a must be completed by July 6, 2020. This deadline, which was previously May 4, 2020, was extended in light of the SEC’s exemptive order, which moved the date by which Industry Members must begin reporting Phase 2b data from May 18, 2020 to July 20, 2020.