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 SSN to the same FDID will result in a rejection.

When multiple trusts (or sole proprietorships) and a Natural Person have the same Tax Identifier (i.e., SSN) and are all CAT Customers associated to the same FDID, Industry Members must report only the Natural Person in association to the FDID with the doingBusinessAs field populated with only one of the trusts that shares the Natural Person’s SSN. The Natural Person 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 Plan Participants are not prescribing a specific methodology for which trust must be reported in the doingBusinessAs field, and any methodology must be applied consistently by the Industry Member.

While the Plan Participants are providing this temporary solution to facilitate the partial reporting of Customer information to CAT, the reporting of only one CAT Customer where two or more CAT Customers are associated to the same FDID is not in compliance with the Plan. The reporting of the Natural Person and trusts with the same SSN as CAT Customers associated to the same FDID may be required in future phases of CAT.

When the trusts and Natural Person have different Tax Identifiers and are all CAT Customers associated to the same FDID, Industry Members must report all versions of the CAT Customers in association to the FDID.