In Phases 2a/2b/2c, these orders must be reported to CAT with a handlingInstructions value of ‘CNH’, denoting Cash Not Held. Starting in Phase 2d, these orders must be reported to CAT with a handlingInstructions value of ‘CASH’, denoting the “cash” order. If the order was also Not Held, the handlingInstructions value of ‘NH’ must also be populated.

Additionally, until December 5, 2022, they must be reported to CAT with a quantity equal to the number of shares that could be purchased with the specified dollar amount based on the best available market at the time of order receipt. For example, if an Industry Member receives a “cash” order for $1,000 when the best available market is $20, then the Industry Member must report a quantity of 50 in the New Order event or Order Accepted event. 

Starting December 5, 2022, Industry Members must begin reporting the ‘CASH’ handlingInstructions with the notional value of the order and may report a quantity value of ‘0’ instead of a calculated quantity. Industry Members should note that the option to report a calculated quantity for “cash” orders will be eliminated starting December 11, 2023, and Industry Members will be required to report a quantity value of ‘0’.

Industry Members need not submit an Order Modified event to reflect a change in share quantity due to market fluctuations during the life of the order. However, if a customer changes the dollar amount resulting in a partial cancellation, then an Order Modified event with a handlingInstructions value of ‘CASH’ must be reported to CAT to reflect that change. Order Cancelled and Order Adjusted events may not be used to report a change in dollar amount. Full cancellations of a “cash” order must be reported using an Order Cancelled event with a cancelQty of ‘0’ and leavesQty of ‘0’.