Per the Full CAIS Technical Specifications, each CAT Customer must only have one active role in association to the FDID at a time. Therefore, an attempt to associate two or more active CAT Customers with the same EIN to the same FDID will result in a rejection.

A disregarded entity is an entity that is disregarded as separate from its owner for federal income tax purposes. When a disregarded entity and its parent company have the same EIN and are both CAT Customers associated to the same FDID, Industry Members must report only one version of the Customer in association to the FDID, either the disregarded entity or the parent company. The CAT Customer must be identified in a role of ‘TRDHOLDER’, which indicates that the CAT Customer is a holder of the account that also has authorization to trade on the account. The data elements reported to CAIS (e.g., Address, Legal Name, LEI, etc.) in association with the Customer Record must be that of the chosen version of the CAT Customer. For example, when the disregarded entity and its parent company have the same EIN but different LEIs, and the Industry Member has reported the parent company as the CAT Customer associated to the FDID, the Industry Member must report the LEI of the parent company. See also FAQ Q4 for additional information regarding the reporting of LEIs for CAT Customers.

While the Plan Participants are providing this temporary solution to facilitate the partial reporting of Customer information to CAT in the context of disregarded entities, the reporting of only one CAT Customer where two CAT Customers are associated to the same FDID is not in compliance with the Plan. Accordingly, the Plan Participants have requested a temporary exemption from the SEC with respect to certain provisions of the CAT NMS Plan relating to this scenario. The reporting of both the disregarded entity and its parent company as CAT Customers associated to the same FDID may be required in future phases of CAT. 

When the disregarded entity and its parent company have different EINs and are both CAT Customers associated to the same FDID, Industry Members must report both versions of the Customers in association to the FDID.