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CAT FAQ M2 states acceptable Firm Designated IDs 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, and would not constitute "Customer Acco

CAT FAQ M2 states acceptable Firm Designated IDs 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, and would not constitute "Customer Account Information" or “Customer Identifying Information” as defined in the CAT NMS Plan. Are there prescribed methodologies for masking account numbers?

No. The Plan Participants are not prescribing any specific methodology that must be used to mask or otherwise transform account numbers for the purposes of reporting the Firm Designated ID (FDID) to CAT. Each Industry Member must, however, ensure the methodology used to mask or otherwise transform an account number does not result in a newly created unique identifier or an internal only identifier that can be used to effect a transaction or would not constitute "Customer Account Information" or “Customer Identifying Information” as defined in the CAT NMS Plan. The same guidance would apply to FDIDs representing a Relationship ID. When selecting an FDID, the Industry Member must also ensure that all vendors and systems can support and use the same FDID for a particular trading account in all CAT Transaction Order events requiring an FDID, and that the same FDID associated with the trading account is submitted to the Customer and Account Information System.