As a general matter, a broker-dealer is considered to be the executing broker in any transaction where its client (either a customer or broker-dealer client) is only able to effect the trade by virtue of the firm’s membership with the applicable market center. Thus, if a client would not be able to effect trades without the firm’s SRO membership, the firm providing the sponsored or direct market access is considered to have received an order from its client and routed it to the market center to which it provides access for the client. Accordingly, such orders must be reported to CAT by the firm providing such access.