Questions for Industry Consideration

Selected Topics of the NMS Plan – Feedback Requested

Selected Topics of the NMS Plan
(new as of 4/22/2013)
Comments on the document should be submitted to by June 14, 2013. Please provide your name and organization when submitting comments. Note that comments received may be published on the website.

Representative Order Proposal - Feedback Requested

Representative Order Proposal

Customer Identifiers
  • How should unique Customer IDs be assigned and by whom?
  • Are there any existing identifiers that could be used?
  • How many Customer ID fields need to be allowed on a new order record?
  • Are there any alternative ways to provide Customer IDs in scenarios where there may be a large number of unique Customer IDs associated with a single account? 
Customer Information
  • How should information of “sufficient detail to identify the customer” be reported? Can it be stored in a customer database rather than be reported with each new order?
  • Do firms have this information readily available for persons authorized to trade in an account that are not account holders?
  • Could firms identify the specific Customer ID that placed on order with a designated field or flag on each new order? 
CAT Reporter ID
  • What should be used for the CAT Reporter ID for broker-dealers? Could CRD# or other existing identifiers be used?
  • How should the CAT Reporter ID be mapped to existing broker-dealer identifiers, such as MPIDs and trading mnemonics? 
  • Should a single identifier that follows an order throughout its life be used, or should a series of order identifiers that can be used to create the full lifecycle of an order be used? 
CAT Intrafirm Order Linkages
  • How can representative orders be linked to underlying customer orders, such as in riskless principal or average price scenarios?
  • How will firms be able to link customer identifiers to average price accounts?
  • What are the primary challenges in linking subaccount allocations to the related parent order?
  • Are there any issues with providing the identity of prime brokers on execution reports? 
Interfirm Order Linkages
  • What are the most significant issues with passing order identifiers between broker-dealers?
  • What should the linkage criteria be for interfirm routes? Should timestamp, shares quantity and other order attributes be part of the criteria or should unique order identifiers be required that would eliminate the need for other linkage criteria such as timestamp? 
Broker-Dealer CAT Order to Exchange Order Linkages
  • What are the most significant issues with linking to a national securities exchange?
  • Are there any issues unique to reporting market-making orders and quotes? 
Data Transmission and Error Correction
  • What data transmission mechanisms should be considered?
  • Does there need to a manual transmission method, such as web entry?
  • What is an achievable timeframe for error corrections, including resubmissions of rejections and unmatched routes?
  • How should errors be communicated to reporting entities? How should data requiring correction be provided to reporting entities?
  • How should the process for correcting unmatched interfirm routes be structured?