Pursuant to the Commission's order granting Exemptive Relief, dated January 23, 2026, all RFQ responses that are communicated in standard electronic format directly to an Industry Member's OMS/EMS or to an RFQ platform and that are not "immediately actionable" (i.e., further action is required before a trade can be executed/routed), to the extent such responses are considered "orders" reportable pursuant to Rule 613(j)(8), are no longer required to be reported to CAT.

As stated in FAQ B44, any equity bid or offer that is accessible electronically by customers or other market participants and is immediately actionable (i.e., no further manual or electronic action is required by the responder providing the quote in order to execute or cause a trade to be executed) is reportable; and any listed option bid or offer which is accessible electronically by customers or other market participants and is immediately actionable (i.e., no further action is required by the responder providing the quote in order to execute or cause a trade to be executed ) is reportable. Accordingly, any response to an RFQ or other form of solicitation response provided in a standard electronic format (i.e. FIX) that meets this definition would be reportable.

Responses communicated in standard electronic format that are immediately actionable are reportable by both the CAT Reporter issuing the RFQ or solicitation (solicitor) and the CAT Reporter responding to the RFQ or solicitation (responder). Specifically, the solicitor must report the receipt of all immediately actionable responses, even those that were not ultimately selected. Non-immediately actionable (NIA) electronic RFQ responses are permanently exempt from CAT reporting.

It is important to note that regardless of the form (electronic or manual) of any RFQ or solicitation response, all orders received or originated as the result of such RFQ or solicitation process must be reported as set forth in the CAT Reporting Technical Specifications for Industry Members. 

Example 1:

A CAT Reporter issues an RFQ through a 3rd party vendor RFQ platform not operated by a broker-dealer. In response to the RFQ, multiple CAT Reporters respond by sending FIX messages directly to the requesting CAT Reporter. Upon selection of a response (either by the trader or automatically by the firm’s trading system), the FIX order from the winning bidder is executed (manually or electronically) OR is routed (manually or electronically) to another broker-dealer or exchange for execution without any further action required by the winning bidder.

The electronically provided responses are reportable by all bidders, even those that were not selected, because the responses are immediately actionable (executable without further action by the responder). Further, the CAT Reporter that issued the RFQ would report the receipt of all immediately actionable responses, as well as any subsequent actions taken to process the order.

Example 2:

A CAT Reporter issues an RFQ and receives several quotes in response through a 3rd party vendor RFQ platform not operated by a broker-dealer. Upon selection of a response, the CAT Reporter either:

• initiates and routes an order electronically to the winning bidder,
• the RFQ platform automatically sends a routed order to the winning bidder, or
• the winning bidder has standing instructions to create a new order acceptance once it receives a message from the RFQ platform that it has won.

The RFQ responses are permanently exempt from CAT reporting because they are not immediately actionable (further action is required by the responder after selection). 

However, the origination of the new order by the solicitor/CAT Reporter, the route of that new order to the winning bidder, and the acceptance of that order by the winning bidder are all reportable events. The solicitor/CAT Reporter would report the new order and route events; the winning bidder would report the order acceptance, as well as any subsequent actions taken to process the order.

Example 3

A CAT Reporter issues an RFQ through a 3rd party vendor RFQ platform not operated by a broker-dealer. In response to the RFQ, multiple CAT Reporters respond by sending FIX messages directly to the requesting CAT Reporter’s OMS. Upon selection of a response, the solicitor CAT Reporter either:

• initiates and routes an order electronically to the winning bidder,
• the RFQ platform automatically sends a routed order to the winning bidder, or
• the winning bidder has standing instructions to create a new order acceptance once it receives a message from the RFQ platform that it has won.

The RFQ responses are permanently exempt from CAT reporting because the CAT Reporters sending the responses would be required to take additional action by accepting a separate order from the requestor before any execution can occur, and would therefore not be considered immediately actionable. 

However, the origination of the new order by the solicitor/CAT Reporter, the route of that new order to the winning bidder, and the acceptance of that order by the winning bidder are all reportable events. The solicitor/CAT Reporter would report the new order and route events; the winning bidder would report the order acceptance, as well as any subsequent actions taken to process the order.

Example 4

An Asset Manager (non-CAT Reporter) issues and receives several quotes in response through a 3rd party vendor RFQ platform that is not part of any CAT Reporter’s OMS/EMS. Upon selection of a response, the Asset Manager either:

• sends a new order request electronically to the winning bidder,
• the RFQ platform automatically sends the new order request to the winning bidder, or
• the winning bidder has standing instructions to create a new order for this Asset Manager once it receives a message from the RFQ platform that it has won.

The RFQ responses are permanently exempt from CAT reporting because they are not immediately actionable. However, the receipt of the order from the Asset Manager, as well as any subsequent actions taken by the winning bidder to process the order are reportable events.