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Are Industry Members that report to CAT using a third-party vendor that submits reportable data to the CAT using a private line connection required to transmit their CAT reportable data to the third party vendor via a private line connection?

Are Industry Members that report to CAT using a third-party vendor that submits reportable data to the CAT using a private line connection required to transmit their CAT reportable data to the third party vendor via a private line connection?

No. The connectivity standards in the CAT NMS Plan (i.e., Section 4.1.1 of Appendix D) only apply to connections directly into the CAT infrastructure. Although the connectivity standards in the CAT NMS Plan would not apply in this scenario, broker-dealers are encouraged to consider industry practices for connectivity designed to mitigate security and other risks.