If one or more third parties (e.g., clearing firms) is used by an Industry Member to report data to CAT, who does the compliance obligation belong to if the third-party reporter is also a CAT Reporter?
Each Industry Member is responsible for the timeliness, accuracy and completeness of the data it is required to report to CAT regardless of who transmits the data to the CAT. Therefore, even if an Industry Member uses another CAT Reporter to report data on its behalf, the Industry Member remains fully responsible for the timeliness, accuracy and completeness of the data. Each Industry Member must have written procedures in place to ensure that the information reported by or on its behalf is timely, accurate, and complete.