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If an account does not have an account holder or authorized trader with an LTID or ULTID, but has other individuals or entities with an LTID or ULTID that may have some other relationship to the account, must that account be reported in the LTID phase of

If an account does not have an account holder or authorized trader with an LTID or ULTID, but has other individuals or entities with an LTID or ULTID that may have some other relationship to the account, must that account be reported in the LTID Phase of CAIS?

Yes. If an LTID or ULTID is associated with an account, it must be reported to CAIS in the LTID Phase. For more guidance regarding an LTID or ULTID being associated with and account, contact the SEC or see the SEC’s Large Trader Rule FAQs. See https://www.sec.gov/divisions/marketreg/large-trader-faqs.htm

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