The reporting obligation for the equity legs of complex orders beginning in Phase 2a is as follows. If a complex order includes an equity leg and the terms and conditions of the order are contingent upon the related option trade, the equity leg must be reported using the handlingInstructions value of ‘OPT’ starting in Phase 2a. This reporting obligation applies regardless of whether the complex order is split or not split into components.

Specifically, for a complex order that is routed or received as a complex order and not split into its constituent equity and option legs, the Industry Member must report the equity leg to the CAT in Phase 2a with the ‘OPT’ handlingInstructions value. For a complex order that is routed or received as a complex order and then split into its constituent equity and option legs and routed, the Industry Member must report the equity leg to the CAT in Phase 2a with the ‘OPT’ handlingInstructions value.

In Phases 2a and 2c, if the complex order contains a net price, Industry Members may report the receipt and route of the equity leg as either a market order, or as a limit order with a price of ‘0’ in accordance with FAQ B58 so long as the handlingInstructions field is populated with a value of ‘OPT’ (refer to FAQ E13 for additional information regarding the handlingInstructions requirements on Order Route events for the equity leg of a complex order). In Phases 2a and 2c, CAT will interpret the combination of a market order with a handlingInstructions value of ‘OPT’, or a limit order with a price of ‘0’ and a handlingInstructions value of 'OPT' as an order with a net price. In Phase 2d, a net price will be required. Refer to the Industry Member Reporting Scenarios document for additional information.

Industry Members will be required to report any simple option leg of a complex order in Phase 2b if the complex order has been split and is being worked as individual legs. Industry Members will be required to report complex orders that include both equity and option components to the CAT in Phase 2d. These reporting obligations apply to both FINRA and non-FINRA members that are Industry Members.