- FAQI6. If an order is received under the US symbol of a foreign security that is an OTC Equity Security, and the customer directs that the order only be executed in a foreign market, is this type of directed order required to be reported if the order is not executed by the end of the CAT Trading day?
No. If the terms of the directed order require the firm to execute the order in a foreign market, and the firm knows that the order will be executed and reported in the foreign market (and thus not subject to transaction reporting under FINRA Rule 6622), the firm would not be required to report to CAT any events related to that order.
- FAQI7. If an order is received under the US symbol of a foreign security that is an OTC equity security and the firm decides to send the order to a foreign market to be executed and reported, but the order ultimately gets executed in the US, does the firm have a CAT reporting obligation?
If the firm has decided to send the order to a foreign market to be executed and reported (and thus there would be no transaction reporting requirement under FINRA Rule 6622), the firm would not be required to report to CAT any events related to that order. However, if, for any reason, the order is ultimately executed in the US (and thus subject to transaction reporting under FINRA Rule 6622), the firm would be required to submit all CAT reportable events related to that order with the original time of order receipt as the eventTimestamp. CAT will mark these events late.
- FAQU13. Which Industry Member has the responsibility for allocation reporting in a piggy back clearing scenario?
When the piggyback firm is fully disclosed, the clearing firm has the obligation to report the allocation. The correspondentCRD field should be populated with the CRD Number of the introducing firm that has the relationship with the customer. For example, Firm A piggybacks on Firm B’s clearing relationship with Clearing Firm C. In this case, the clearing firm should populate the correspondentCRD field with Firm A’s CRD Number.
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 Allocation Amendment event must be reported to CAT reflecting the corrected details of the allocation. Changes that do not impact CAT reportable attributes are not required to be reported to CAT as allocation amendments. For example, an allocation is booked to an account at 5:15 pm. Subsequently, at 6:30 pm, the clearing firm updates a CAT reportable attribute.
Yes. An Allocation Report is required when executed shares/contracts are allocated to an account when the account is purchasing shares (shares are placed in account) and when the account is selling shares (shares are delivered from the account). Designation of a purchase or sale is reported as the “side” of the allocation.
Concurrent with Phase 2c (April 26th 2021), LTIDs or ULTIDs associated with FDIDs must be reported in the LTID phase of CAIS (“CAIS LTID”) when BOTH of the following conditions are met:
- FAQQ21. What are the deadlines for reporting in the CAIS LTID phase after the first Reportable Event in the account with an associated LITD or ULTID occurs?
The general rule is that accounts (FDIDs) with associated LTIDs or UTLIDs must be reported to CAIS by 8:00 a.m. Eastern on the day after the first Reportable Event for the account (FDID) occurs. For example,
- FAQQ22. If an account does not have an account holder or authorized trader with an LTID or ULTID, but has other individuals or entities with an LTID or ULTID that may have some other relationship to the account, must that account be reported in the LTID phase of CAIS?
Yes. If an LTID or ULTID is associated with an account, it must be reported to CAIS in the LTID phase. For more guidance regarding an LTID or ULTID being associated with and account, contact the SEC or see the SEC’s Large Trader Rule FAQs. See https://www.sec.gov/divisions/marketreg/large-trader-faqs.htm
Yes. If an introducing broker or non-self-clearing executing broker has Reportable Events for an account with associated LTIDs or ULTIDs, they must report such accounts to CAIS LTID as described in FAQ Q20.
Yes. See Section 7 (Certify Testing Completion) in the Industry Member CAIS Onboarding Guide.