As noted in FAQ Q44, if multiple addresses are associated with a particular account, then Industry Members must submit these additional addresses to CAIS if such address information is reasonably available. Further, FAQ Q44 states that in instances where an Industry Member maintains separate addresses at the account and customer level, then all such reasonably available addresses must be reported to CAIS.

While various addresses associated with a particular Account or Customer are of regulatory significance, the Plan Participants recognize that Industry Members may save several addresses in their records, some of which may contain legacy information. The requirement to report additional address information maintained by the Industry Member is not intended to change or supersede the Industry Members’ obligations to collect or maintain customer and account address information. Outside of Industry Members’ existing record keeping requirements and applicable SRO and SEC rules, there are no additional CAT CAIS-specific requirements to validate, audit or otherwise update and maintain such additional addresses by or at the time they are initially reported to CAT CAIS along with the full set of Customer and Account information with the implementation of Phase 2e (Full CAIS). Notwithstanding the above, additional addresses should be reported in the appropriate format to CAT CAIS.