The CAT NMS Plan requires that Industry Members report addresses at the Customer level. In response to industry feedback that broker-dealers generally maintain addresses at the account level rather than at the Customer level, Participants implemented a temporary technical solution that allowed a Customer to be reported to CAIS without an address and permitted Industry Members to report a minimum of one address for each account rather than an address for each Customer.

On September 13, 2021, the Participants requested exemptive relief from the requirement that Industry Members report addresses at the Customer level. The Commission has not acted on this request. Accordingly, there is no exemptive relief that would allow an Industry Member to report only addresses at the account level.

Therefore, effective July 12, 2023, each Customer must be reported to CAIS with at least one address (up to four addresses), and the requirement to report at least one address at the FDID level will remain. Further, Industry Members that reported Customers to CAIS without a Customer level address must report a Customer level address for such Customers to CAIS by no later than July 12, 2023.

Separately, effective August 7, 2023 in the Production Environment, a new validation will reject Customer Records submitted to CAIS without at least one address reported at the Customer level. Error Code 22514, which is currently in production, will be enhanced to cover this new validation on a go-forward basis.