If executions against an order are tracked throughout the day but a single average price fill is provided to the client after the order is completed or at the end of the day, are fulfillments required throughout the day with a fulfillment amendment requirement with each new execution?
No. A single Order Fulfillment reflecting the final average price fill to the client order is required. A Fulfillment Amendment would only be appropriate if the fill to the client was changed after the final fulfillment had been provided to the client. Some systems may provide intraday transparency to the progress of executing an order as informal information that is not considered by the firm to be ‘final’ fulfillments, and these should not be reported to CAT as fulfillments and fulfillment amendments.