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What date should Industry Members use to populate the “end date” fields (e.g., fdidEndDate, roleEndDate) when an event has triggered the closure of an account? For example, when a minor reaches the age of majority for a custodial account (e.g., UGMA/UTMA)

What date should Industry Members use to populate the “end date” fields (e.g., fdidEndDate, roleEndDate) when an event has triggered the closure of an account? For example, when a minor reaches the age of majority for a custodial account (e.g., UGMA/UTMA) or upon the death of an account holder for a beneficiary account, how should Industry Members populate these fields?

If the Industry Member’s practice is to close an account and open a new account in the scenario where there is a triggering event, the Industry Member must populate the “end date” fields with the date that is maintained in its books and records.

The updated record is required to be reported to CAT CAIS by 8:00 a.m. Eastern Time on the CAT Trading Day following the day the Industry Member confirmed the date in its books and records.

For example, the date of death of an account holder was January 1. The beneficiary notified the Industry Member on February 1 and requested closure of the account, but did not provide the required documentation (e.g., death certificate) until February 15. On February 16, the Industry Member confirmed the death of the account holder and started processing the account closure. The Industry Member must populate the “end date” fields with the date that is maintained in its books and records. However, the updated record is due by 8:00 a.m. Eastern Time on February 17 (assuming February 17 is a CAT Trading Day).
 

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