In the event that a CAT Reporter has multiple valid Input Identifiers for a CAT Customer who is associated with a single account at the firm, then the CAT Reporter will need to select one of the Input Identifiers based on the following criteria.
If there is more than one Input Identifier type for the CAT Customer, then CAT Reporter Firms must follow the hierarchy as outlined in Section 2.2.5 of the Full CAIS Technical Specifications for Industry Members. Specifically, if a US-assigned Input Identifier (i.e., SSN/ITIN or EIN) is available for the CAT Customer, then the CAT Customer must be reported to CAIS using a Transformed Identifier (TID) generated from the US-assigned Input Identifier.
- For example, a dual citizen Natural Person CAT Customer provides a CAT Reporter with both a valid SSN and a National Identity Card for a country outside of the United States. In this example, the CAT Reporter firm would generate the TID value from the SSN.
In the event the CAT Customer does not have a US-assigned Input Identifier but has more than one foreign Input Identifier of a specific type– such as multiple Tax Identifiers or multiple Legal Entity Identifiers (LEI) values – then the CAT Reporter Firm must determine which value is the primary, current value. If multiple values are current, the CAT Reporter firm must select the Input Identifier from the country/municipality of the primary incorporation or residence of the customer.
- For example, a Legal Entity CAT Customer is currently legally registered in both the United Kingdom and France, and provides the CAT Reporter with a Tax Identifier for both locations. The Customer indicates and/or the CAT Reporter ascertains that the United Kingdom is the primary incorporation of the Legal Entity. In this example, the CAT Reporter would use the Tax Identifier for the United Kingdom to generate the TID value.