As outlined in FAQ Q40, all Active Accounts with activity on or after June 12, 2022 must be reported to CAIS with the implementation of Phase 2e (Full CAIS). Industry Members are required to report the current state of the customer information and account records in effect at the time the account is first required to be reported to the CAIS Production Environment. Per CAT Alert 2022-01, subsequent updates and changes to customer and account information must be reported to CAIS no later than November 7, 2022.

For example, a customer relocated from Address A to Address B in August 2022, and is residing at Address B on October 15, 2022 when Industry Member 1 is required to report this record to CAIS. The customer no longer has any association to Address A as of October 15, 2022. In this example, Industry Member 1 would only be required to report the current state of the account and customer information to CAIS (i.e., Address B) on October 15, 2022.