Whether the Industry Member should be identified as a CAT Customer on the FDID Record 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), the Industry Member is not required to be identified as a CAT Customer on the related FDID Record when there are standing instructions on the account (such as the Industry Member purchase of shares in an Automated Investment Plan or Dividend Reinvestment Plan) or when an order is placed by the Industry Member to satisfy a legal requirement or SEC/SRO rule, such as a liquidation to satisfy a margin call. In addition, assuming the Industry Member is not an account holder and has not been given authority to place orders for the account without prior approval of the account holder(s), the Industry Member is not required to be identified as a CAT Customer on the related FDID Record when liquidating fractional shares held in a Customer’s account to facilitate operational processes (e.g., ACAT, an Industry Member buying a fractional share from a customer upon receipt of an order to exit its entire position in a security, or orphaned fractional positions). If an Industry Member uses a firm owned or controlled account to trade fractional positions against a Customer account, the Industry Member must report that firm owned or controlled account to CAIS. 

See the section titled “Fractional Share Scenarios” in the CAT Industry Member Reporting Scenarios document for more information regarding the transaction reporting requirements for fractional share scenarios.

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.