For the month of September 2021, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host the Monthly CAT Implementation Update on the second Thursday, September 9, 2021, at 4:15 pm ET. The Monthly CAT Implementation Update meetings provide the industry with a high level overview of materials and guidance published on the www.catnmsplan.com website during the month.Audio file
On September 7, 2021 at 4:15 p.m. Eastern Time, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host an industry webinar for ARCAOP members regarding the opportunities and procedures for testing CAT submissions from the ARCAOP Pillar mandatory Saturday industry tests.Audio file
Consolidated Audit Trail, LLC and FINRA CAT, LLC will host a monthly Industry Testing Checkpoint Call for CAIS/LTID on Wednesday, September 1, 2021 at 4:15 pm ET.
Please note that FINRA CAT, LLC utilizes 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. This webinar will be recorded. The presentation document and recording will be posted.Audio file
- FAQB42. Are Industry Members required to report the receipt of a cancellation or modification instruction to the CAT if the order is terminal (i.e., it has already been fully executed or cancelled)?
Industry Members are not required to report an Order Modification Request or Order Cancel Request event to CAT to the extent the order is terminal at the time of the request (i.e., the order has already been fully executed or cancelled) in Phase 2d. This activity may be required in future phases of CAT.
- FAQE2. Are Industry Members required to report to the CAT the routing of an order if the routed order is rejected by the Industry Member or Participant to which the order is routed?
Yes, if the Industry Member routes an order to another Industry Member or a Participant, the Industry Member must report the routing of the order to the CAT. The details that must be reported for the routing of an order are set forth in Section 6.3(d)(ii) of the CAT NMS Plan, as applied to Industry Members by Section 6.4(d)(i) of the CAT NMS Plan. While all routes are required to be reported to CAT, Order Route events for orders that were rejected by the Industry Member or Participant to which the order was routed are not required to be reported in Phases 2a (equity) or 2b (options).
- FAQU8. Are allocations to a registered investment advisor (RIA)/money manager’s average price account required to be reported even if the shares are only held there temporarily before being allocated to individual customer accounts? For example, an RIA manages two customer accounts at a self-clearing firm. The RIA places a single order in its account that will be later allocated between the two customer accounts. The shares are booked to an average price account designated for the RIA at the self-clearing firm until the RIA provides subaccount allocation instructions and the allocations are made to the individual customer accounts.
Yes, all allocations to customer accounts are required to be reported even if the shares are only held there temporarily. In this scenario, the self-clearing firm would have to report the allocation to the RIA’s average price account as well as the subaccount allocations to the individual customer accounts.
- FAQU9. What value should be used to populate the eventTimestamp in the Post-Trade Allocation event (MEPA) or Option Post-Trade Allocation event (MOPA)?
The eventTimestamp on an Allocation event should reflect the date and time when the shares or contracts allocated are booked into the customer or client’s account. For firms that have multiple “booking times” that are captured in their backend system, this is the booking time that reflects the placement of shares or contracts into the customer account.
No. CMTAs are not allocations, as defined by SEC Rule 613. Therefore, CMTAs are not required to be reported to CAT. However, CMTAs may optionally be reported to CAT in the Option Post-Trade Allocation (MOPA) and Option Amended Allocation (MOOA) events using the allocationType value of ‘CMTA’ and populating the occClearingMemberID field.
- FAQU14. When may the Amended Allocation/Option Amended Allocation (MEAA/MOAA) events be reported to CAT?
If an allocation is updated such that a CAT reportable attribute is changed after the shares/contracts have been booked in a customer or client account, then an Amended Allocation event (MEAA) or Option Amended Allocation Event (MOAA) may be reported to CAT reflecting the corrected details of the allocation.
- FAQU16. Are accounts maintained by a clearing firm that are owned or controlled by another broker-dealer considered “customer” accounts for purposes of reporting Allocation Reports to CAT? For example, shares are booked into the average price account of an Introducing Broker (IB) dealer before the IB provides allocation instructions to the final customer accounts. Is the booking of shares into the IB owned or controlled average price account required to be reported as an Allocation by the clearing firm to CAT?
No, allocations to any account owned or controlled by a broker-dealer are not required to be reported to CAT as Post-Trade Allocation (MEPA) or Option Post-Trade Allocation (MOPA) events. Allocations to an account owned or controlled by a broker-dealer may be voluntarily reported to CAT but must be properly identified as such using the correct allowable value in the allocationType field. Note that average price accounts designated exclusively for a specific customer (not a broker-dealer) are always considered customer accounts.