The infoBarrierID field allows firms to uniquely identify on an order-by-order basis each information barrier that meets the criteria of the “no-knowledge” exception for certain proprietary trading activity under FINRA Rule 5320. By identifying specific information barriers that are in place with respect to individual orders, both customer and proprietary, Industry Members will provide CAT with information that can be used when conducting reviews of compliance with FINRA Rule 5320. Specifically, on all events for orders received or originated at a desk or department with an information barrier in place, Industry Members must populate the infoBarrierID with the value assigned by the Industry Member to the specific information barrier in instances where the firm is claiming the “no-knowledge” exception. The use of this field allows each customer and proprietary order to be identified with a particular information barrier.

For example, if an Industry Member has two or more separate desks or departments that share a single information barrier, orders received or originated at these separate desks or departments may be reported to CAT with the same unique infoBarrierID. If, alternatively, an Industry Member has separate desks or departments that are not within the same information barrier, orders received or originated at these desks or departments would be reported to CAT with different Information Barrier IDs. Finally, if an order is received or originated within an Industry Member that has no information barriers in place, those orders must be reported to CAT with the inforBarrierID field left blank. To the extent that Industry Members populate the infoBarrierID field, the use of values must remain consistent. Therefore, once used, a value may not be reassigned to identify a different information barrier.

Reporting Scenarios

Scenario #1 – Desks or Departments Sharing an Information Barrier
• Example: Firm A has a customer facing desk (Desk 1) and a proprietary desk (Desk 2) within the same information barrier that the firm has named “AB12”. Desk 1 receives an order from a customer and Desk 2 originates a proprietary order. The CAT reporting would be as follows:

Scenario #2 – Desks or Departments Separated by Information Barriers
• Example: Firm A has a customer facing desk (Desk 1) that is within an information barrier the firm has named “U89T” and a proprietary desk (Desk 2) that is within an information barrier the firm has named “4RYH”. Desk 1 receives an order from a customer and Desk 2 originates a proprietary order. The CAT reporting would be as follows:

Scenario #3 – Desks or Departments with No Information Barriers Example:
• Example: Firm A has a customer facing desk (Desk 1) and a proprietary desk (Desk 2), neither of which have information barriers in place. Desk 1 receives an order from a customer and Desk 2 originates a proprietary order. The CAT reporting would be as follows: