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Are transfers of positions between accounts within the same legal entity reportable to CAT?

Are transfers of positions between accounts within the same legal entity reportable to CAT?

No. Journals and other non-trading, internal position transfers between accounts within the same legal entity generally are not reportable, as they do not involve the receipt or origination of an order or a bid or offer under Rule 613(j)(8), or other Reportable Event. However, position transfers are subject to applicable SRO rules, and if an exchange rule requires a position transfer to be transacted on an exchange, orders originated to effect a transfer and related Reportable Events would be reportable to CAT. In addition, while position transfers within the same entity generally are not reportable to CAT, the origination and internal routing of an order by one part of an Industry Member to a different desk or department for subsequent handling and any related Reportable Events are reportable to CAT.