What are an Industry Member's CAT reporting obligations when a US symbol is not available on the day an order is received and executed? For example, an order is received and executed on Monday at which time a symbol is requested. The symbol, however, is not issued until Wednesday.
Industry Members receiving orders in foreign equity securities without a US symbol for which they have a trade reporting obligation must: 1) promptly request a symbol; and 2) comply with the CAT recording requirements under the Plan. Once a symbol becomes available, the Industry Member must report the trade to FINRA pursuant to FINRA Rule 6622 and report all applicable information to CAT in accordance with the Plan. Data submitted to CAT with an Event Timestamp prior to the symbol issuance date will not be marked late. Industry Members may, however, be asked to demonstrate that a symbol was promptly requested upon execution of the trade.