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Suppose that an Industry Member receives a simple electronic order for a Listed Option. The Industry Member then engages in a solicitation process to identify a contra party to pair the order against for execution on an exchange, and one or more market participants respond to the solicitation of interest. The Industry Member selects one or more of the responding market participants’ order(s) to execute against the original order, and sends a paired order(s) to an exchange for execution.

In Phase 2b, the Industry Member may populate any of the side values applicable to sell orders (i.e., SL, SS, SX). Starting in Phase 2d, the only value applicable to options sell orders is 'S'. 

On Wednesday, May 5, 2021 at 4:15 pm ET, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host an industry webinar to review the requirements for translating Input Identifiers of CAT Customers to Transformed Identifier Values. All Industry Members are required to report Transformed Identifier Values for CAT Customers to the Customer and Account Information System (CAIS) beginning in July 2022. This webinar will also provide an overview of the paired files submission process for the CAIS Data file and Transformed Identifiers file.

If an equity order is tied to stock, fixed income, futures, or another product that is not reportable to CAT at a net price (or other formula such as a specific delta no later than Phase 2d), Industry Members must populate the appropriate handlingInstructions value of ‘TTS’, ‘TTF’, ‘TTO’, ‘TTU’, or ‘FUT’. This activity does not meet the definition of a multi-leg order, as these trading strategies do not contain an option leg, and must continue to be reported to CAT as equity order events in Phase 2d.

Allocation events for shares/contracts initially booked to an account or changes to shares/contracts that were initially booked to an account prior to April 26, 2021 (Phase 2c - Equities) or December 13, 2021 (Phase 2d – Options) are not required to be reported to the CAT. This includes any actions subsequent to the initial booking, such as allocation amendments or cancel/rebills. 

The purpose of this document is to provide a roadmap to assist Small Firms meet their CAT reporting obligations for CAT Reportable Securities not currently reported to OATS by December 13, 2021. This document is comprised of two parts. Part 1 lays out steps necessary to be able to report order data to the CAT Transaction System. Part 2 lays out steps necessary to be able to report customer and account data to the CAT Customer and Account Information System (“CAIS”).