For both phases, the CAT NMS Plan requires Industry Members to report Received Industry Member Data, which includes customer and account data, by 8:00 a.m. Eastern Time on the CAT Trading Day following the day the Industry Member receives such Received Industry Member Data. See CAT Alerts 2022-01 and 2023-01 for the Full CAIS Implementation Schedule. 

For example:

If the Industry Member receives Received Industry Member Data before 4:15 p.m. ET on T, then the Customer and Account data must be reported by 8:00 a.m. ET on T+1.

If the Industry Member receives Received Industry Member Data after 4:15 p.m. ET on T, then the Customer and Account data must be reported by 8:00 a.m. ET on T+2.

Also, as stated in FAQ Q43, while a firmDesignatedID value of ‘PENDING’ is acceptable for Transaction reporting, CAT CAIS will reject a firmDesignatedID value of ‘PENDING’. Thus, once the FDID becomes available, the Industry Member must report the actual FDID to CAT CAIS along with all other required Customer and Account information by 8:00 a.m. ET on T+1.

Received Industry Member Data not reported within these timeframes will not be marked late by the Plan Processor but will be subject to review by the applicable SRO.

See the Reporting and Repair Deadlines and Examples from the May 4, 2021 CAIS Technical Specification Working Group.