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Before the reporting of Customer Account Information and Customer Identifying Information begins in July 2022 regulatory users of the CAT will use FDIDs to identify whether the same account is trading within a single broker-dealer. After the reporting of Customer Account Information and Customer Identifying Information begins, FDIDs will be used to link accounts to specific customers, including mapping accounts with common ownership (for instance, where a customer is associated with more than one FDID).
Industry Members (other than Small Industry Members) and Small Industry Members that are required to record and report information to FINRA’s Order Audit Trail System pursuant to applicable SRO rules (“Small Industry OATS Reporters”) must report FDIDs for the original receipt or origination of an order that is required to be reported in Phase 2a to the CAT beginning on June 22, 2020. Small Industry Members that are not OATS Reporters must report the FDID when they begin submitting data to CAT on December 13, 2021.
On Wednesday, May 20, 2020 at 2:30 pm ET, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host an industry webinar focusing on Intrafirm Linkage.
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.Audio file
- EventAudio file
Like a negotiated transaction, both the buyer and seller of the reportable security in an EFP transaction would have an obligation to report New Order events and Trade events at the time the transaction occurs. The New Order event should contain the handlingInstructions value of EW to identify it as an EFP.
- FAQB9. Are all messages, as represented in order routing protocols such as FIX, required to be reported to CAT by Industry Members?
No. Industry Members only are required to report the “details for each order and each Reportable Event, as applicable,” as set forth in Section 6.3(d) of the CAT NMS Plan, as applied to Industry Members by Section 6.4(d)(i) of the CAT NMS Plan. The definitions of “orders” and “Reportable Events” are set forth in Section 1.1 of the CAT NMS Plan. If a message in an order routing protocol does not meet the definition of an order or a Reportable Event, then details related to that message do not have to be reported to the CAT.
All timestamps submitted in STRING format must be reported to CAT in Eastern Time. Timestamps submitted in UTC must not be adjusted for Eastern Time. For additional information, refer to the CAT Reporting Technical Specifications for Industry Members.
- FAQI3. If an order in a foreign security is broken up and executed across multiple markets, both foreign and domestic, what are the CAT reporting obligations?
Orders received for foreign equity securities traded in the US must be reported if any resulting executions are subject to the requirements of FINRA Rule 6622. In this example, since part of the order is executed over the counter in the US and therefore subject to the requirements of FINRA Rule 6622, the firm would have an obligation to record and report a New Order event reflecting the receipt of the order, an Order Route event for each component sent abroad, an Order Fulfillment event for the portion executed abroad and a Trade event for each component executed in the US.Topics
- CAT Alert
The CAT Industry Member Test and Production Environments for Phases 2a and 2b are being rolled out with implementation of different types of validations, (i.e. data integrity, linkage) at different times. This CAT Alert describes the Industry Member CAT Reporting Test Plan for Phases 2a/2b and how Industry Members may leverage data submissions to the Test and Production Environments to test their compliance with linkage validations, prior to the formal Compliance Go-live dates.
- FAQD15. If the handlingInstructions reported with an order contains instructions that reflect the order is only eligible to be traded at the time it is received, such as "Fill or Kill", or implies the time the order is eligible, such as "Market on Open", is the tradingSession field still required to be populated?
Yes. The tradingSession field must be populated on all orders. However, if because of the specific nature of the handling instruction (e.g., Fill or Kill), the customer does not provide further information on the trading sessions in which the order may trade, it would be acceptable for the tradingSession field to be populated with "ALL" since no specific Trading Session was communicated by the customer to the Industry Member.Topics