If an issue symbol is delisted and is no longer tradable on any market because the security is no longer valid, then no MEOC is required for GTC orders in that symbol, as this scenario would be considered an implicit cancellation. Industry Members choosing to optionally report this activity should be mindful that any errors received as a result of the symbol having been delisted on the Event Date would not be repairable.

Similarly, if a corporate action (e.g., merger/acquisition) occurs in which a security is no longer valid, and the symbol becomes associated with a new security, no MEOC would be required for the original security. For example, if there is an open GTC order in symbol ABC and ABC is acquired and no longer trades on any market, no MEOC is required.

However, explicit cancellations are required for any cancelled GTC orders and are reportable using the symbol on the list in the following scenarios. 

•    If the issue symbol changed and there is no change to the underlying security. For example, if a security trades under symbol ABC and changes its symbol to XYZ.  A cancel event is not required for ABC (the original order) but would be required for the new symbol, XYZ.

•    The symbol was delisted from one market and continued to trade on another market (either under the same symbol or a different symbol). For example, ABC traded over-the-counter and then listed on an Exchange under a new symbol XYZ.  A cancel event is not required for ABC (the original order) but would be required for the new symbol, XYZ.

Industry Members are responsible for identifying material changes to an underlying security from corporate action announcements and taking appropriate action to ensure compliance with their books and records and CAT transaction reporting requirements.