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If an Industry Member CAT Reporter uses multiple reporting vendors for both Transaction and Customer and Account reporting, should the same FDID be reported by each vendor on behalf of the Industry Member CAT Reporter?

If an Industry Member CAT Reporter uses multiple reporting vendors for both Transaction and Customer and Account reporting, should the same FDID be reported by each vendor on behalf of the Industry Member CAT Reporter?

Yes. CAT allows multiple vendors to submit data on behalf of a single Industry Member CAT Reporter. Each vendor reporting Transaction Order events requiring a Firm Designated ID (FDID) on behalf of an Industry Member CAT Reporter would have to provide the same FDID as required. A single FDID assigned to each trading account must be unique, persistent and consistent within the firm and across all vendors, and unique across time. An Industry Member CAT Reporter must ensure that the same FDID is used by all vendors and systems submitting Transaction Order Events requiring an FDID to CAT involving the same unique trading account at the Industry Member. It would not be acceptable for different vendors or systems to use different FDIDs to represent the same unique trading account. The Industry Member must also ensure that the same FDID used for a particular trading account in CAT Transaction reporting is submitted to the Customer and Account Information System. The same guidance would apply to an FDID value representing a Relationship Identifier (“Relationship ID”) or Entity Identifier (“Entity ID”).