Is the use of a Relationship ID to populate the FDID if the account structure is not available at the time of order receipt limited to only institutions?
No. If the trading account structure of an individual customer is not available when a new order is first received, as with an institutional client in the same circumstances, the Industry Member may populate the FDID with an identifier used by the firm to represent the individual customer’s trading relationship with the Industry Member (“Relationship ID”). Please note that the Participants will make any filings with the SEC, as necessary, to reflect this guidance.