A broker-dealer systematized a Customer’s account information on a specific date, but the new account form was dated with a date prior to the systematized date. Is it permitted for the broker-dealer to report the later systematized date as the fdidDate on the related FDID Record?
Prior to the CAT CAIS Implementation date (May 31, 2024), in this case where there are multiple dates associated with an account, CAT Reporters should report the fdidDate that is reasonably available. See CAT NMS Plan, Article 1, Section 1.1 definition of “Account Effective Date”. For example, if a CAT Reporter has physical account papers located in an offsite storage system and a different systematized date, both of which indicate that the account was opened prior to the CAT CAIS Implementation date, it is reasonable to use the systematized date as the fdidDate.
After the CAT CAIS Implementation date (May 31, 2024), the CAT Reporter must use the date that is reflected in its books and records as the fdidDate.
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Yes