Does the requirement that broker-dealers report on actionable indications of interest pursuant to Rule 606, under the Securities Exchange Act of 1934, change what is reportable to CAT?
No. The changes to Rule 606 do not modify what is reportable to CAT. Under the CAT, broker-dealers must determine whether trading interest falls within the definition of “order” for CAT purposes. As noted in CAT FAQB3, for CAT purposes, an IOI is a non-firm expression of trading interest that contains one or more of the following elements: security name, side, size, capacity and/or price. If trading interest is firm, that trading interest is reportable under CAT (regardless of how it is labeled).