As noted above, the Full CAIS Technical Specifications require the Natural Person first and last names be reported in two separate fields. In the scenario where the Industry Member has historically maintained the Customer name in an unparsed state and will not be able to complete parsing of all Customer names by the implementation schedule set forth in CAT Alerts 2022-01 and 2023-01, the Plan Participants will temporarily make available a value of ‘UNPARSED’ to be populated in the firstName field. The unparsed name must be populated in the lastName field. Further, as soon as practicable, but no later than June 12, 2023, the Industry Member must resubmit the Customer Record to CAIS with the first and last names parsed and in the required separate firstName and lastName fields.

Use of the ‘UNPARSED’ value in the firstName field is only allowable until June 12, 2023. While the Plan Participants are providing this temporary solution to allow Industry Members to report the Customer Record to CAIS according to the implementation schedule set forth in CAT Alerts 2022-01 and 2023-01, an unparsed first and last name is not in compliance with the Plan and the Operating Committee-approved Technical Specifications which require that the first and last names be reported in separate fields. There is no exemptive relief that would allow the entry of Customer names in an unparsed state. Accordingly, use of the ‘UNPARSED’ value could be subject to review by Regulators.

An “Unparsed Names” Report will be made available to regulators and affected Industry Members. ‘UNPARSED’ will be retired from the Full CAIS Technical Specifications effective June 13, 2023.