- Reference Material
Consolidated Audit Trail, LLC and FINRA CAT, LLC will host a monthly Industry Testing Checkpoint Call for CAIS/LTID on Wednesday, April 7, 2021 at 4:15 pm ET.
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- FAQQ42. A broker-dealer systematized a Customer Record on a specific date, but the Customer had opened an account with the firm prior to that date. Is it permitted for the broker-dealer to report the later date when the broker-dealer systematized the Customer record as the account effective date?
In this case where there are multiple dates associated with an account prior to the CAT CAIS Implementation date (July 11, 2022), CAT Reporters should report the account open date that is reasonably available. (See CAT NMS Plan, Article 1, Section 1.1 definition of “Account Effective Date”). For example, if a CAT Reporter has physical account papers located in an offsite storage system and a systematized date, both of which were opened prior to the CAT CAIS Implementation date, it is reasonable to use the systematized account effective date.
- CAT Alert
This CAT Alert describes the Industry Member CAT Reporting Test Plan for Phase 2c and how Industry Members must transition from Phase 2a/2b to Phase 2c data submissions to the Industry Member Test and Production Environments. This CAT Alert also describes how FINRA CAT will provide support during the transition period between Phase 2a/2b and Phase 2c.
- FAQU26. Are Industry Members that are a clearing firm required to report the booking of shares into a customer account that result from an options exercise or other non-CAT reportable transaction to CAT?
No. As noted in FAQ K4, options assignments and exercises are not orders, as defined by SEC Rule 613, and therefore are not required to be reported to CAT. Therefore, Industry Members are also not required to report the resulting booking of shares into a customer account resulting from an options assignment or exercise.
- FAQU24. Is an Industry Member that is a clearing broker required to report an allocation report before all required information about the allocation is known? Specifically, allocations to DVP accounts require the DVPCustodianID field to be populated. How would the clearing firm report an allocation report if the DVPCustodianID is not yet available?
Because the identity of the prime broker is a required element on the allocation report to a DVP account, the allocation report cannot be reported to CAT until the DVPCustodianID is known to the clearing broker. The allocation eventTimestamp should represent the time all required elements, including the DVPCustodianID, are known to the Industry Member clearing broker.
- FAQU19. How should the DVPCustodianID field in the Post-Trade Allocation event (MEPA) be populated when an allocation involves a foreign entity for which a DTC number is known?
The DVPCustodianID field in the Post-Trade Allocation event (MEPA) should accurately reflect the settlement instructions on the account (not the entity) to which shares are placed or from which shares are delivered at settlement. A Depository Trust Company (DTC) number should be reported if the account where the shares are allocated will settle the transaction via DTC.
- FAQQ15. If an Industry Member ends an LTID to FDID association for a legitimate reason (such as the customer no longer qualified as a large trader), and later is required to reestablish it, what should the ltidEffectiveDate be?
If an LTID to FDID association is ended for a legitimate reason and must be reestablished, the Industry Member should populate the ltidEffectiveDate with the date on which the LTID or ULTID became re-associated to the FDID within the CAT Reporter’s system- not the original LTID Effective Date.
- Technical Specifications