With respect to the Industry Members’ reporting obligations, when two broker-dealers have entered into a sponsored access agreement whereby one broker-dealer sponsors the other broker-dealer into a specific market center (such as a national securities exchange) by providing use of the sponsoring broker-dealer’s SRO-assigned identifier, both broker-dealers have separate and distinct CAT reporting obligations. For example, if BD A sponsors access into a national securities exchange for BD B, the CAT reporting obligation for each broker-dealer would be as follows:

Sponsored Broker-Dealer BD B (under the SRO-assigned identifier of BDBB)
New Order Event
Order Route Event indicating order was routed to BDA

Sponsoring Broker-Dealer BD A (under the SRO-assigned identifier of BDAA)
Order Accepted Event indicating the order was received from BDBB
Order Route Report indicating order was routed to a national securities exchange

The CAT reporting obligations outlined above are the same regardless of the type of connection used by the sponsored broker-dealer to access the applicable market center. For example, the CAT reporting obligations for each broker-dealer would be the same whether the sponsored broker-dealer used a direct market connection provided by the sponsoring broker-dealer, a third party service provider connection provided by the sponsoring member, or its own proprietary connection to the subject market center.