No. Sensitive Identifiers are defined in the Customer and Account Information Technical Specifications as Social Security Number and Individual Taxpayer Identification Identifiers. Industry Members must not provide Sensitive Identifiers, nor full dates of birth for individuals, nor account numbers for customer accounts to the CAT.  In light of security concerns raised with regard to the maintenance of Customer information in the CAT, the SEC granted exemptive relief on March 17, 2020 that would eliminate the requirement to report these three data elements [

].  Instead of these three elements, Industry Members will be required to report to the CAT a transformed value for Sensitive Identifier and year of birth for individuals, and a Firm Designated ID ("FDID") for each account. Further, actual customer account numbers may not be used for FDID. See FAQ Section M for detailed guidance for FDIDs. 

Further, a Sensitive Identifier, date of birth or account number must not be submitted to CAIS as a value for any field in the record including firmDesignatedID and accountName, unless it is masked. In the scenario where a Sensitive Identifier, date of birth or account number is part of the account name in an Industry Member’s books and records, it is expected that the masked accountName value submitted to CAIS will not match the unmasked account name in an Industry Member’s books and records.  

In addition, Industry Members must not submit to CAIS, in any field of the record, any other number associated with the customer’s account that could be used to effect a transaction in the account.