As stated in FAQ F5, Industry Members are required to link a Representative Order with the underlying order(s) that it represents. There are limited instances where linkage is required at the client fill level rather than the order level using the Firm Designated ID (“FDID”) of the firm owned or controlled account from which the customer order was filled. Specifically, for orders that are originated in different systems that are not linked in an Industry Member’s systems, such as a customer order originated in an Order Management System (“OMS”) and represented by a principal order originated in an Execution Management System (“EMS”) that is not linked to the OMS, Industry Members are required to link the fill of the customer order to the FDID of the firm owned or controlled account that was used to originate and execute the Representative Order. Further, such Representative Orders must be reported to CAT with an indicator reflecting the order is eligible for customer fills from an unlinked system. Appendix C of the Industry Member Technical Specifications provides details of the required linkages in these workflows. 

All Industry Members will be required to provide representative order linkages to unlinked OMS/EMS and position fill scenarios no later than July 31, 2025 due to the expiry of the exemptive relief granted by the SEC on January 17, 2025. 

The only Representative Order workflow in which linkage is not required at either the order level or the fill level is that in which a firm receives a client order, guarantees an execution price (e.g., GVWAP) and then originates proprietary orders in an effort to work the client order. Because the client order may not ultimately be filled from the proprietary order(s) if the guaranteed price is not achieved, direct linkage is not required. Although direct linkage is not required to the client fill, the proprietary orders originated to work the client order must be marked as a Representative Order and designated as part of a price guarantee scenario. Appendix C of the Industry Member Technical Specifications provides the specific reporting requirements for price guarantee scenarios.