Are there any scenarios where an Industry Member can assume another CAT Reporter will report an order to CAT on its behalf absent any specific reporting agreement between the two CAT Reporters?
No. There are no scenarios where one CAT Reporter has an obligation to report orders on behalf of another Industry Member that uses its systems to route or execute orders. An agreement to use any third party for reporting to CAT must be agreed to by the two parties, evidenced in writing, and retained by both parties to the agreement. The agreement must specify the respective functions and responsibilities of each party. An Industry Member cannot assume that any third party will perform reporting on its behalf.