In this situation, the minor or incapacitated person must be reported to CAIS with a role of ‘TRDHOLDER’ with the doingBusinessAs field populated with the value of ‘PUBLIC ADMINISTRATOR’. The Authorized Traders Names List must be included with the submission, and include the name of the government employee public administrator (e.g., U.S. state, county or municipality government employee). 

It is understood by the Plan Participants that a Customer Record with a role of ‘TRDHOLDER’ paired with the ‘PUBLIC ADMINISTRATOR’ value populated in the doingBusinessAs field represents a minor or incapacitated account holder who does not have authorization to trade on the account, and that the associated FDID Record is associated with a government employee Authorized Trader acting in the capacity as of a conservator or guardian for the account holder. This is an interim technical solution to allow these FDIDs to be accepted into CAIS prior to Full CAIS Compliance go-live. This guidance is specific to the scenario where the Natural Person government employee (rather than the Legal Entity) is appointed as the Authorized Trader.

The Industry Member may choose to report such Customer Records to CAIS in the manner outlined above so that the associated FDID Records can be accepted into CAIS and not be rejected due to Error Code 22071. However, given the limited number of FDID Records associated with this guardianship/conservatorship and government employee Authorized Trader fact-pattern, the Industry Member may also opt to resubmit such records to CAIS in the manner described above to CAIS following receipt of Error Code 22071 in its feedback. There currently is no exemptive relief that would allow an Industry Member not to report Customer Identifying Information for U.S. government employee Authorized Traders under Rule 613. In this situation, where the government employee Authorized Trader does not provide a year of birth or Input Identifier citing exemptions from the definition of “customer” under the Customer Identification Program Rule (31 CFR § 1023.100(d)), the Plan Participants are providing a temporary technical solution to allow an Industry Member to report the government employee Authorized Trader in the Authorized Trader Names List, rather than reporting a Customer Record. As noted in FAQ Q65, use of the Authorized Trader Names List is not in compliance with the Plan, is only allowable on a temporary basis and, with sufficient time and notice, will be retired from the Full CAIS Technical Specifications at a future date. Thus, Industry Members will be required to resubmit the FDID Record to CAIS with all required data for a full CAT Customer Record.

The Plan Participants will provide further guidance on this scenario before retirement of the Authorized Trader Names List and are evaluating the mechanism for reporting government employee public administrators to CAIS.