Interpretive FAQ

Consolidated Audit Trail ("CAT") Frequently Asked Questions for Industry Members

The following sets forth Frequently Asked Questions regarding the CAT requirements applicable to Industry Members ("CAT Industry Member FAQs"). Questions regarding the FAQs should be directed to the CAT Help Desk. Capitalized terms used here, but not otherwise defined, shall have the meanings ascribed to them in the CAT NMS Plan.

Q1. Are indications of interest ("IOIs") or requests for quotes ("RFQs") reportable to the CAT? added 2/13/18
A1. No, neither IOIs nor RFQs are reportable to CAT, as neither falls within the definition of an "order" as set forth in the CAT NMS Plan. For CAT purposes, an IOI is a non-firm expression of trading interest that contains one or more of the following elements: security name, side, size, capacity and/or price. The CAT treatment of IOIs is consistent with FINRA’s treatment of IOIs under the OATS reporting requirements. (See OATS Compliance FAQ C76 available at http://www.finra.org/industry/faq-oats-compliance-faq)

Q2. Is a CAT Reporter required to report two separate timestamps for Manual Order Events? added 2/13/18
A2. Yes, a CAT Reporter is required to report two separate timestamps for Manual Order Events that are entered into an electronic system. If an order is received manually and then later entered into an electronic system for further handling and execution, the CAT Reporter must report both the manual receipt time and the Electronic Capture Time. Specifically, CAT Reporters are required to record and report: (1) the time of a Manual Order Event in increments up to and including one second; and (2) the time when a Manual Order Event has been captured electronically in an order handling and execution system of the Participant or Industry Member ("Electronic Capture Time") in milliseconds. (See Section 6.8 of the CAT NMS Plan available at https://www.catnmsplan.com/wp-content/uploads/2017/03/34-79318-exhibit-a.pdf)

Q3. When an order is routed internally at an Industry Member, Section 6.3(d)(ii)(F) of the CAT NMS Plan ("routing of an order"), as applied by Section 6.4 of the CAT NMS Plan, requires the reporting of the identity and nature of the department or desk to which the order is routed. What is considered "routed internally"?
added 2/13/18
A3. For purposes of Section 6.3(d)(ii) of the CAT NMS Plan, an order is considered to have been routed internally at the Industry Member when the Industry Member originates or receives an order and then subsequently transmits that order to another desk or department within the Industry Member. A desk or department is interpreted as a place or system within the Industry Member where an order can be executed, either automatically or with the assistance of traders. Examples of a desk or department include an agency desk, sales desk or arbitrage desk. The Industry Member, however, is not required to report information regarding an order’s movement between two systems within the same desk or department as an internal route. The CAT reporting requirements for internal routes within an Industry Member are consistent with FINRA’s OATS reporting requirements for internal routes within a broker-dealer. (See OATS Technical Reporting Specifications (Jan. 20, 2017), Section 4.2.2 (Transmittal to a Desk or Department within a Firm), Section 4.4.5 (Partial Desk Transmittal and Subsequent Execution), Section 4.4.6 (Desk Transmittal to another Desk or Department and Subsequent Execution and Routing), Section 4.4.15 (Single Desk Usage of Multiple Order Handling Systems), and Section 4.4.17 (Multiple Desk Usage of Multiple Order Handing Systems) available at http://www.finra.org/sites/default/files/TechSpec_012017.pdf)

Q4. Are CAT Reporters required to record and report information related to any securities other than NMS Securities and OTC Equity Securities to the CAT?
added 2/13/18
A4. No. CAT Reporters are not required to record and report information related to non-Eligible Securities to the CAT. CAT Reporters only are required to report information related to Reportable Events in Eligible Securities – that is, NMS Securities and OTC Equity Securities. (See Section 1.1 of the CAT NMS Plan (definition of Eligible Security) available at https://www.catnmsplan.com/wp-content/uploads/2017/03/34-79318-exhibit-a.pdf)

Q5. If a non-US broker-dealer routes an order to a US broker-dealer, how is the US broker-dealer required to report the receipt of the order to the CAT?
added 2/13/18
A5. The receiving US broker-dealer is required to report the receipt of an order from a non-US broker-dealer in the same way as it would report the receipt of an order from a Customer. Specifically, the receiving US broker-dealer would report the receipt of this order as the original receipt of the order from the non-US broker-dealer, and the receiving US broker-dealer would report the Firm Designated ID of the Customer, which is the non-US broker-dealer. The US broker-dealer would not report the ultimate customer of the non-US broker-dealer.

Q6. Are all Industry Members required to report NBBO information to the CAT? added 2/13/18
A6. No, only CAT Reporters that are ATSs are required to submit NBBO information to the CAT. Specifically, ATSs would be required to report certain NBBO information upon the receipt and execution of an order. The CAT reporting requirement for ATS NBBO information is consistent with FINRA’s OATS reporting requirements for ATS NBBO information. (See FINRA Rule 4554)

Q7. Are orders in foreign securities reportable? added 2/21/18
A7. The origination or receipt of an order involving any security that meets the definition of an NMS security pursuant to SEC Rule 600 must be reported to the CAT, regardless of where the order is ultimately executed. If the order is sent to a foreign market for execution, the CAT Reporter is required to report the relevant Reportable Events for the order (e.g., origination or receipt of the order and the routing of the order to the foreign market). All prices must be converted into U.S. dollars based on the conversion rate applicable at the time of the transaction.

Orders in foreign equity securities that do not meet the definition of an NMS stock pursuant to SEC Rule 600 are required to be reported only in those instances where the resulting execution is subject to the transaction reporting requirements in FINRA Rule 6622. The requirements of FINRA Rule 6622 do not apply to transactions in foreign equity securities provided that: (1) the transaction is executed on and reported to a foreign securities exchange; or (2) the transaction is executed over the counter in a foreign country and is reported to the regulator of securities markets of that country.

The CAT reporting requirement for foreign securities is consistent with FINRA’s OATS reporting requirements for foreign securities. (See OATS OTC FAQs for Foreign Equity Securities Traded in the US and Foreign Equity Securities available at http://www.finra.org/industry/faq-oats-otc-faq;
and OATS for all NMS Stocks FAQ 6 available at http://www.finra.org/industry/faq-oats-all-nms-stocks-faq)

Q8. Are CAT Reporters required to report to the CAT quotes received via subscriptions to receive market data from market data vendors (such as exchanges or market data aggregators)? added 3/13/18
A8. No. CAT Reporters are not required to report to the CAT quotes received via subscriptions to receive market data from market data vendors. Under Sections 6.3(d)(iii) and 6.4(d)(i) of the CAT NMS Plan, CAT Reporters are required to report certain data to the CAT “for the receipt of an order that has been routed.” Although such quotes may fall within the definition of an “order” under the CAT NMS Plan (and SEC Rule 613(j)(8)) as “bids” and “offers,” such quotes have not been routed to the CAT Reporter, and therefore, not subject to the reporting requirement.

Q9. If a Reportable Event is priced in a non-U.S. dollar currency, how will such prices be reported to the CAT? added 4/4/18
A9. If a Reportable Event is priced in a non-U.S. dollar currency, CAT Reporters are required to convert such prices into U.S. dollars based on the conversion rate applicable at the time that the Reportable Event occurred and report such prices to the CAT in U.S. dollars. The treatment of prices in non-U.S. dollar currencies is consistent with FINRA’s treatment of such prices under OATS reporting requirements (See Compliance FAQ C71 available at: http://www.finra.org/industry/faq-oats-compliance-faq).

Q10. How should an Industry Member report timestamps to the CAT if its order handling and order execution systems use different timestamp increments?
added 4/4/18
A10. Section 6.8 of the CAT NMS Plan requires that “[e]ach Participant shall, through its Compliance Rule: (i) require that, to the extent that its Industry Members utilize timestamps in increments finer than the minimum required in this Agreement in their order handling or execution systems, such Industry Members shall utilize such finer increment when reporting CAT Data to the Central Repository.”  This requirement is reflected in each Participant’s CAT compliance rule series. Therefore, to the extent that any Industry Member’s order handling or execution systems utilize timestamps in increments finer than milliseconds for a given Reportable Event, such Industry Member shall record and report that Reportable Event to the CAT with timestamps in such finer increment. To the extent that an Industry Member has order handling or execution systems that utilize timestamps with varying increments, the Industry Member shall use the timestamps associated with each relevant system and Reportable Event when reporting CAT Data to the Central Repository, provided that in all instances such timestamps meet the minimum requirement of 1 millisecond for non-Manual Order Events.

Q11. Are Industry Members required to report to the CAT all messages related to the transmission of an order? added 4/18/18
A11. No. Industry Members only are required to report the “details for each order and each Reportable Event, as applicable,” as set forth in Section 6.3(d) of the CAT NMS Plan, as applied to Industry Members by Section 6.4(d)(i) of the CAT NMS Plan. The definitions of “orders” and “Reportable Events” are set forth in Section 1.1 of the CAT NMS Plan. If a message does not meet the definition of an order or a Reportable Event, then details related to that message do not have to be reported to the CAT. For additional information on reporting to the CAT, please see Section F (Reporting) of the General Frequently Asked Questions (FAQs) About the CAT.

Q12. Are Industry Members required to report the receipt of an order to the CAT if the Industry Member rejects the order? added 4/18/18
A12. If the Industry Member receives an order, the Industry Member must report the receipt of the order to the CAT. The details that must be reported for the receipt of an order are set forth in Sections 6.3(d)(i) (for the original receipt of an order) and 6.3(d)(iii) (for the receipt of an order that has been routed) of the CAT NMS Plan, as applied to Industry Members by Section 6.4(d)(i) of the CAT NMS Plan.

Q13. Are Industry Members required to report to the CAT the routing of an order if the routed order is rejected by the Industry Member or Participant to which the order is routed? added 4/18/18
A13. If the Industry Member routes an order to another Industry Member or a Participant, the Industry Member must report the routing of the order to the CAT. The details that must be reported for the routing of an order are set forth in Section 6.3(d)(ii) of the CAT NMS Plan, as applied to Industry Members by Section 6.4(d)(i) of the CAT NMS Plan.

Q14. How would an Industry Member determine the time of order receipt?
added 4/18/18
A14. If an Industry Member receives an order, the Industry Member must report the time of order receipt pursuant to Sections 6.3(d)(i) (for the original receipt of an order) and 6.3(d)(iii) (for the receipt of an order that has been routed) of the CAT NMS Plan, as applied to Industry Members by Section 6.4(d)(i) of the CAT NMS Plan. The time of order receipt for Sections 6.3(d)(i)(E) and 6.3(d)(iii)(C) is the time that the Industry Member receives the order.

Q15. Will the CAT be ready to accept Industry Member Data in November 2018? If not, when will Industry Members be required to begin reporting to the CAT?
added 5/1/18
A15. While SEC Rule 613(a)(3) and Section 6.7(a) of the CAT NMS Plan require that Participants begin reporting to the CAT by November 15, 2017, Industry Members (other than Small Industry Members) begin reporting to the CAT by November 15, 2018, and Small Industry Members begin reporting to the CAT by November 15, 2019, the CAT System currently is not operational and will not begin to accept order or customer data submissions from Industry Members until after November 15, 2018. Moreover, the Operating Committee has not yet approved a final version of the Industry Member Technical Specifications. In November 2017, the Participants requested an extension of these reporting deadlines so that Participants would begin reporting to the CAT by November 15, 2018, Industry Members (other than Small Industry Members) would begin reporting to the CAT by April 13, 2020 and Small Industry Members would begin reporting to the CAT by April 20, 2021 (see also Section C (Timelines and Implementation) of the General Frequently Asked Questions (FAQs) About the CAT). As of the date of this FAQ, the SEC has not granted the Participants’ request to extend the CAT reporting deadlines. The Operating Committee expects that Industry Members will begin reporting to the CAT after Participants begin reporting to the CAT and after a final version of the Industry Member Technical Specifications has been approved and published with sufficient time for development and testing. The Operating Committee will keep the industry informed of the timing for reporting to the CAT.

Q16. Should Industry Members begin coding their CAT reporting systems based on the current draft of the Industry Member Technical Specifications?
added 5/1/18
A16. No. As of the date of this FAQ, the Operating Committee has not approved a final version of the Industry Member Technical Specifications. As noted in all draft versions of the Industry Member Technical Specifications made available to the industry to date, the drafts are for discussion purposes only, not final, should not be used for coding and have not been formally approved by the Operating Committee. The Participants will continue to engage with the industry with respect to the Industry Member Technical Specifications and the Operating Committee will notify the industry when iterative drafts of the Industry Member Technical Specifications are published, as well as when the final Industry Member Technical Specifications are formally approved.

Q17. If an Industry Member holds a peg order, is the Industry Member required to report to the CAT a modification to the peg order every time the market moves?
added 5/16/18
A17. Each time an Industry Member reprices a peg order based on a market move (i.e., when there is a change in the national best bid or offer or the best bid or offer on a particular exchange, as applicable based on the terms of the order), the Industry Member must report a price modification of the peg order to the CAT pursuant to Section 6.3(d) of the CAT NMS Plan, as applied to Industry Members by Section 6.4(d)(i) of the CAT NMS Plan, if the price is modified. If the Industry Member does not reprice a peg order when the market moves, the Industry Member does not need to report a modification of the peg order to the CAT since the order was not modified by either the customer or the Industry Member. For example, for both displayed and non-displayed alternative trading systems (ATSs), if an ATS’s matching engine reprices a peg order when the market moves, the price modification must be reported to the CAT. If a matching engine does not reprice a peg order when the market moves, there is no requirement to report a price modification to the CAT.

Example 1: A display ATS receives a buy order with a primary peg instruction and a limit price of $10. The current market is 9.98 and accordingly, the order is displayed at 9.98. The NBB subsequently moves to 9.99. The ATS reprices the order and re-displays it at 9.99. The re-pricing of this order must be reported to CAT by the ATS.

Example 2: An ATS receives a buy order with a primary peg instruction and a limit price of $10. The order is not displayable or routable and the ATS has no sell orders that are eligible to trade with the buy order. The NBB subsequently moves to 9.99 and the ATS receives no other sell orders that are eligible to trade with the buy order. The ATS takes no action on the open buy order when the NBB moves to 9.99, therefore there is no CAT reportable event.

Example 3: An ATS receives a buy order with mid-point peg instruction when the NBBO is 9.85 x 10. The order is not displayable or routable and the ATS has no sell orders that are eligible to trade with the buy order. The NBBO subsequently moves to 9.90 x 10. The ATS then receives a market order to sell that is eligible to trade with the buy order and the two orders are crossed at 9.95. Because the ATS did not re-price the buy order prior to executing it, there is no CAT reportable event required to reflect a price modification of the buy order to 9.95.

Q18. How has the Operating Committee defined “Trading Day”?
added 10/30/18
A18. The Operating Committee has determined that “Trading Day” shall have the following meaning for all Eligible Securities. For Participant CAT Reporters the Trading Day is defined as beginning after midnight on one trade date and ending at midnight the next trade date. For Industry Member CAT Reporters, Trading Day is defined as beginning immediately after 4:15:00 p.m. and no fractions of a second Eastern Time on one trade date and ending at exactly 4:15:00 p.m. and no fractions of a second Eastern Time on the next trade date.

Q19. What is a Firm Designated ID (“FDID”)?
added 8/15/18
A19. FDID is defined in Section 1.1 of the CAT NMS Plan as “a unique identifier for each trading account designated by Industry Members for purposes of providing data to the Central Repository, where each such identifier is unique among all identifiers from any given Industry Member for each business date.”

Under the CAT NMS Plan broker-dealers are required to report the FDID on each new order submitted to the Central Repository and the Central Repository will associate specific customers and their Customer IDs with individual order events based on the reported FDID. Given the purpose of the FDID under the CAT NMS Plan, it is important that this identifier be consistent across each business day of a broker-dealer.

Q20. Can actual account numbers be used as the FDID when submitting data to CAT?
added 8/15/18
A20. The use of an actual account number as the FDID is prohibited to ensure the capture of sensitive data in CAT is minimized when its inclusion is not required to achieve the objectives of CAT. Specifically, the Operating Committee has determined that Industry Members must not assign as an FDID a customer’s account number or any other number associated with the customer’s account that could be used to effect a transaction in the account. Acceptable FDIDs may include, without limitation, a newly created unique identifier or an internal only identifier used by a broker-dealer that cannot be used to effect a transaction. Industry Members also may employ a masking methodology that would mask the actual account number prior to submission to CAT so that it could still be used by CAT to identify a single trading account within the Industry Member, but the identifier provided to CAT could not be used to effect a transaction in the account.

Please note that a proposed amendment to the CAT NMS Plan will be filed to reflect the use of FDID as described in this interpretive FAQ.

Q21. Can FDIDs change each Trading Day?
added 8/15/18
A21. No. Unless a new account or entity identifier is assigned to a client or customer, each FDID must be unique and persistent for each trading account on any given business day so that a single account may be tracked across time within a single broker-dealer. For example, if an Industry Member assigns a new account or entity identifier to a client or customer for any reason, such as due to a merger, acquisition or some other corporate action, then a new FDID may be created to identify the new account identifier/entity identifier in use at the Industry Member for the entity.

Q22. Which FDID must be provided in scenarios involving managed accounts where an order may be placed in a master account with subaccount allocations made at a later time?
added 8/15/18
A22. The account or entity identifier used to place the order must be reported. In scenarios where a master/top account or entity identifier is used to place an order, the FDID representing the master/top account or entity identifier should be reported to CAT. In such scenarios, the FDID represents the master/top account or entity that is authorized to place orders for one or more legal entities or customers.

Q23. Which FDID must be provided for firm owned or controlled accounts?
added 8/15/18
A23. The FDID representing the account identifier used by the firm for the specific firm owned or controlled account in which the order was originated should be reported to CAT. For example, firms must specify whether an account used for a Reportable Event was a market making account, other proprietary trading account, agency allocation account or error account.

Q24. If an Industry Member CAT Reporter uses multiple reporting vendors, should the FDID be reported by each vendor submitting new order events on behalf of the Industry Member CAT Reporter?
added 8/15/18
A24. Yes. CAT allows multiple vendors to submit data on behalf of a single Industry Member CAT Reporter. Each vendor reporting new order type events on behalf of an Industry Member CAT Reporter would have to provide the FDID as required. An Industry Member CAT Reporter must ensure that the same FDID is used by all vendors submitting Reportable Events to CAT involving the same unique trading account at the Industry Member. It would not be acceptable for different vendors to use different FDIDs to represent the same unique trading account.

Q25. How will regulators use the FDID?
added 8/15/18
A25. Before the reporting of Customer Account Information and Customer Identifying Information begins on November 15, 2021 for Industry Members (other than Small Industry Members) and on November 15, 2022 for Small Industry Members, regulatory users of the CAT will use FDIDs to identify whether the same account is trading within a single broker-dealer. After the reporting of Customer Account Information and Customer Identifying Information begins, FDIDs will be used to link accounts to specific customers, including mapping accounts with common ownership (for instance, where a customer is associated with more than one FDID).

Please note that a proposed amendment to the CAT NMS Plan will be filed to reflect the phased approach for Industry Member CAT reporting.

Q26. When will Industry Members be required to report the FDID to the CAT?
added 8/15/18
A26. The Participants will permit Industry Members (other than Small Industry Members) and Small Industry Members that are required to record and report information to FINRA’s Order Audit Trail System pursuant to applicable SRO rules (“Small Industry OATS Reporters”), but not require, to report FDIDs for the original receipt or origination of an order that is required to be reported in Phase 2a to the CAT from November 15, 2019 through February 24, 2020. After February 24, 2020, all Industry Members that are required to report the original receipt or origination of any order must report FDIDs for such original receipt or origination of any order.

Please note that a proposed amendment to the CAT NMS Plan will be filed to reflect the phased approach for Industry Member CAT reporting.

Q27. How should Industry Members report transactions involving fractional shares to the CAT?
added 9/11/18
A27. CAT will accept reports involving fractional shares; please refer to the Industry Member Technical Specifications for additional details.

Q28. What types of products will be in scope for purposes of Industry Members reporting details of Orders and Reportable Events to the CAT?
added 9/11/18
A28. Industry Members will be required to report to the CAT details for each Order and Reportable Event involving an Eligible Security. Under the CAT NMS Plan, “Eligible Security” includes: (1) all NMS Securities, meaning “any security or class of securities for which transaction reports are collected, processed, and made available pursuant to an effective transaction reporting plan, or an effective national market system plan for reporting transactions in Listed Options”; and (2) all OTC Equity Securities, meaning “any equity security, other than an NMS Security, subject to prompt last sale reporting rules of a registered national securities association and reported to one of such association’s equity trade reporting facilities.” While the CAT NMS Plan does not define “prompt last sale reporting rules,” the Operating Committee has determined that transactions in restricted securities (as defined by SEC Rule 144(a)(3)) are not reportable to CAT because they are not subject to prompt last sale reporting rules. However, transactions in direct participation programs (DPPs) must be reported to CAT in Phase 2c of Industry Member reporting. Thesys CAT, the Plan Processor for the CAT, will begin publishing daily lists of Eligible Securities no later than March 30, 2019.

Q29. Can Small Industry Members that are not OATS Reporting Members (“Small Industry Non-OATs Reporters”) voluntarily report to the CAT prior to November 15, 2020?
added 10/17/18
A29. Yes, Small Industry Non-OATS Reporters may voluntarily choose to begin reporting prior to November 15, 2020, the date on which Small Industry Non-OATS Reporters are required to begin reporting to the CAT. However, if a Small Industry Non-OATS Reporter begins reporting at such earlier date, (1) it must report all CAT Data required to be reported by Industry Members in accordance with the CAT Compliance Rules, the CAT NMS Plan and the Industry Member Technical Specifications, as if it were required to report such CAT Data; and (2) it may not cease to report to the CAT once it begins reporting to the CAT.

Q30. Can CAT Reporting Agents report CAT Data to the CAT on behalf of an Industry Member without the Industry Member’s consent?
added 10/17/18
A30. No, a CAT Reporting Agent may not report CAT Data to the CAT on behalf of an Industry Member without the Industry Member’s consent. As required in the CAT Compliance Rules, an Industry Member may enter into an agreement with a CAT Reporting Agent pursuant to which the CAT Reporting Agent agrees to fulfill the obligations of such Industry Member under the CAT Compliance Rules. Any such agreement is required to be evidenced in writing and the agreement must specify the respective functions and responsibilities of each party to the agreement that are required to effect full compliance with the requirements of the CAT Compliance Rules. Such agreement should include the date on which the CAT Reporting Agent should commence reporting to the CAT on behalf of the Industry Member. In addition, to begin reporting to the CAT, the Industry Member and the CAT Reporting Agent must complete the onboarding process with the Plan Processor. Notwithstanding the existence of an agreement with a CAT Reporting Agent, an Industry Member remains primarily responsible for compliance with the CAT reporting requirements.

Q31. What Industry Member Data will be reportable to the CAT during Phase 2b of the revised implementation schedule?
added 10/17/18
A31. During Phase 2b of the revised implementation schedule, Industry Members will be required to report to the CAT Industry Member Data related to Eligible Securities that are options and that is related to Simple Electronic Option Orders, excluding Electronic Paired Option Orders. “Simple Electronic Option Orders” mean orders to buy or sell a single option that are not related to or dependent on any other transaction for pricing or timing of execution that are either received or routed electronically by an Industry Member CAT Reporter. “Electronic Paired Option Orders” mean electronic option orders that contain both the buy and sell side that is routed to another Industry Member or exchange for crossing and/or price improvement as a single transaction on an exchange. Further, the events related to Simple Electronic Option Orders subject to reporting in Phase 2b are limited to those events which involve electronic receipt of an order, or electronic routing of an order. Electronic receipt of an order is defined as the initial receipt of an order by an Industry Member in electronic form in standard format directly into an order handling or execution system. Electronic routing of an order is the routing of an order via electronic medium in standard format from one Industry Member’s order handling or execution system to an exchange or another Industry Member.

Q32. Are quotations in OTC Equity Securities that are sent by an Industry Member to foreign exchanges reportable to CAT?
added 10/17/18
A32. Quotations in OTC equity securities sent to foreign exchanges are required to be reported only in those instances where a resulting execution is subject to the transaction reporting requirements in FINRA Rule 6622. The requirements of FINRA Rule 6622 do not apply to transactions in foreign equity securities that are not NMS Stocks provided that: (1) the transaction is executed on and reported to a foreign securities exchange; or (2) the transaction is executed over the counter in a foreign country and is reported to the regulator of securities markets in that country. Note that the guidance in Interpretive FAQ #7 applies to quotations since quotations are “orders” under the CAT NMS Plan.

Q33. Are Industry Members required to report the equity leg of a complex order in Phase 2a of the revised implementation schedule?
added 10/17/18
A33. During Phase 2a of Industry Member CAT reporting, Industry Members must report the equity leg of a complex order as a simple equity order using the “OPT” special handling code. This is consistent with the handling of such orders in OATS. During Phase 2d, Industry Members will be able to report complex orders to the CAT that include both equity and option components.

Q34. What is the definition of “foreign broker-dealer” for purposes of populating the originator and destination type fields for Industry Member reporting?
added 10/30/18
A34. For purposes of reporting to the CAT, the Participants have adopted the definition of “foreign broker-dealer” as set forth in SEC Rule 15a-6(b)(3).  In particular, SEC Rule 15a-6(b)(3) states: “The term foreign broker or dealer shall mean any non-U.S. resident person (including any U.S. person engaged in business as a broker or dealer entirely outside the United States, except as otherwise permitted by this rule) that is not an office or branch of, or a natural person associated with, a registered broker or dealer, whose securities activities, if conducted in the United States, would be described by the definition of ‘broker’ or ‘dealer’ in sections 3(a)(4) or 3(a)(5) of the [Securities Exchange Act of 1934].”

Q35. Are responses to auctions reportable in phase 2b?
added 10/30/18
A35. Yes. Responses to auctions of simple orders and paired simple orders are reportable in phase 2b.  The order must be reported with a handling instruction of “AucResp” and the Auction ID must be reported in a name/value pair.