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”) must commence reporting Firm Designated IDs (FDID) on all Transaction Order events requiring an FDID to the CAT in Phase 2a beginning on June 22, 2020. Small Industry Members that are not Small Industry OATS Reporters must commence reporting FDIDs on all Transaction Order events requiring an FDID to the CAT by December 13, 2021.