No.  A customer’s account number must not be submitted to the Transaction system or the Reference Database and therefore cannot be used as the firmDesignatedID (FDID) value, in whole or in part. Further, an FDID value must not contain any information that could be used to identify a customer (including, but not limited to, a social security number, name or date of birth) or any other information that could be used to effect a transaction in the customer’s account. In addition, an actual relationship identifier must not be submitted to the Transaction system or the Reference Database and therefore cannot be used as the firmDesignatedID (FDID) value. 

Acceptable FDIDs may include, without limitation, a newly created unique identifier or an internal only identifier used by an Industry Member that cannot be used to effect a transaction or identify a customer. The Plan Participants are not prescribing any specific methodology that must be used to mask or otherwise transform customer account numbers or relationship identifiers for the purposes of reporting the FDID to CAT. Each Industry Member must, however, ensure the methodology used to mask or otherwise transform an account number or relationship identifier does not result in a newly created unique identifier or an internal only identifier that can be used to effect a transaction or identify a customer. 

Actual proprietary account numbers of an Industry Member may be used as the firmDesignatedID value. Each Industry Member must make its own determination as to whether it believes it is necessary to mask the actual account number for any proprietary account of the firm when reporting the FDID to CAT.