The CAT contains information about orders, quotes, and transactions for all NMS Securities (i.e., exchange-listed equities and options), as well as OTC Equity Securities across U.S. markets, including related events such as origination, modification, cancellation, routing, and execution, reported by Industry Members and Plan Participants to the order and trade subsystem. This includes a limited set of associated customer and account information reported by Industry Members to the segmented Customer Account and Information Subsystem (CAIS). Industry Members are directed not to report social security numbers, customer account numbers, or dates of birth to CAIS.
a. What is Customer Account Information and Customer Identifying Information?
SEC Rule 613 requires that the CAT collect certain information about each customer in a securities transaction. In March 2020, and prior to the collection of any customer information, the SEC approved an exemption requested by the Plan Participants to eliminate the requirement for Industry Members to report social security numbers, customer account numbers, and birthdates to CAIS. Specifically, pursuant to the exemption, Industry Members are to report the following Customer Account Information and Customer Identifying Information to CAIS:
Customer Account Information includes information such as account type, account status, and key account dates (e.g., date account opened, closed). Industry Members are prohibited from reporting customer account numbers to CAIS.
Customer Identifying Information includes, with respect to individuals, information such as name, address, year of birth (NOT the full date of birth), and role in the account (e.g., primary holder, joint holder, etc.) Industry Members are PROHIBITED FROM REPORTING SOCIAL SECURITY NUMBERS (SSNs) TO CAIS. In lieu of submitting SSNs, Industry Members generate and report a Temporary Identifier (TID). This TID is further tokenized by the Plan Processor to create an internal CAT Customer Identifier (CCID) that is not to be shared outside of CAT. This process, referred to as the “CCID Alternative” in the March 17, 2020 SEC Order, implements a CCID generation strategy that insulates the CCID generation process from the CAT Central Repository and avoids the need for Industry Members to submit SSNs to CAIS. The CCID Alternative was developed in consultation with Industry Member security experts and was facilitated by the Securities Industry Financial Markets Association (SIFMA).
b. Must social security numbers, customer account numbers, or dates of birth be reported to CAIS?
No. In March 2020, the SEC approved the Plan Participants’ exemptive request to eliminate the requirement for Industry Members to report social security numbers, full dates of birth, and customer account numbers to CAIS. Reporting specifications explicitly provide that Industry Members are prohibited from reporting such information to CAIS. Instead of reporting full date of birth, reporters are required to report only year of birth for Natural Persons.