If an Industry Member has received a “Not Held” order, which only gives the Industry Member discretion as to the price and time of execution of the order, must the Industry Member be identified as a CAT Customer on the related FDID Record in CAIS?
Whether the Industry Member should be identified as a CAT Customer depends on whether the Industry Member is an account holder or has authority to place orders for the account without prior approval of the account holder(s). Absent this authority from the account holder(s) (and assuming the Industry Member is not an account holder in this scenario), receipt of a “Not Held” order does not require that the Industry Member be identified as a CAT Customer on the related FDID Record.
See FAQ Q56 for more information regarding when a natural person who is employed by an Authorized Trader must be identified as a CAT Customer.
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Yes