The CAT reporting requirements depend on what reporting error(s) the Industry Member made as well as whether the FINRA Facility allows a trade report to be corrected without cancelling the original trade report. The different FINRA Facilities have different functionality with regards to correcting and cancelling trade reports. For more information on reporting cancellations, corrections, and reversals to the TRF/ADF/ORF, see Section 311 of FINRA’s Trade Reporting FAQs.

Below are descriptions and CAT reporting requirement for four different trade cancellation and correction scenarios. 

Scenario 1: An Industry Member executes a trade for 1,000 shares and correctly reports the MEOT to CAT for 1,000 shares but incorrectly reports the trade to a FINRA Facility for 100 shares. The FINRA Facility allows for corrections of trade reports without cancelling the original trade report and links the corrected trade report by reference to the original trade report. The Industry Member corrects the trade report to 1,000 shares without cancelling the original trade report and the Compliance ID or FINRA Control Number on the corrected trade report remains the same as the Compliance ID or FINRA Control Number on the original trade report.

In this scenario, the Industry Member is only required to report a single MEOT linking to the original trade report because the data in the MEOT was correct and it will link to the original trade report which will link by reference to the new trade report.

Scenario 2: An Industry Member executes a trade for 1,000 shares and correctly reports the MEOT to CAT for 1,000 shares but incorrectly reports the trade to a FINRA Facility for 100 shares. The FINRA Facility does not allow for corrections of trade reports so the Industry Member must cancel the original trade report and enter a new one. The Industry Member enters the same Branch Sequence Number on the corrected trade report as was on the original (cancelled) trade report. 

In this scenario, the Industry Member is only required to report a single MEOT because the data in the MEOT was correct and it will link to both the original (cancelled) trade report and the new trade report via the tapeTradeID/Branch Sequence Number since the Industry Member entered the same Branch Sequence Number on the corrected trade report as was on the original (cancelled) trade report.

Scenario 3: At 10 am, an Industry Member executes a trade at 9.99 and reports the MEOT to CAT with a price of 9.99. At 10:01 am, the Industry Member then realizes that the trade should have been executed at 9.98 so it cancels the original trade report and enters a new trade report at 9.98 and execution time of 10:01 am. 

In this scenario, the Industry Member is required to report two MEOTs- one linking to the original (cancelled) trade report and a second linking to the new trade report. Otherwise, the Industry Member will receive trade linkage errors. 

Scenario 4: An Industry Member executes a trade for 1,000 shares but incorrectly reports the MEOT to CAT for 100 shares and incorrectly reports the trade to a FINRA Facility for 100 shares. The FINRA Facility allows for corrections of trade reports without cancelling the original trade report and links the corrected trade report by reference to the original trade report. The Industry Member corrects the trade report to 1,000 shares without cancelling the original trade report and the Compliance ID or FINRA Control Number on the corrected trade report remains the same as the Compliance ID or FINRA Control Number on the original trade report.

In this scenario, the Industry Member is required to link the MEOT for 100 shares to the original trade report for 100 shares and then submit a correction (actionType= ‘COR’) of the MEOT to correct the share quantity to 1,000 shares. The ‘COR’ MEOT will link to both the original trade report and the corrected trade report via the tapeTradeID/Compliance ID or FINRA Control Number since the Industry Member entered the same Branch Sequence Number on the corrected trade report as was on the original (cancelled) trade report.