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Can a fully disclosed introducing broker-dealer and its clearing firm use the same firmDesignatedID (FDID) for New Order events (MENO)/New Option Order events (MONO) and Post-Trade Allocation event (MEPA)/Option Post-Trade Allocation event (MOPA)?

Can a fully disclosed introducing broker-dealer and its clearing firm use the same firmDesignatedID (FDID) for New Order events (MENO)/New Option Order events (MONO) and Post-Trade Allocation event (MEPA)/Option Post-Trade Allocation event (MOPA)?

The clearing firm may know the introducing broker-dealer’s FDIDs, in which case the firmDesignatedID in the introducing broker-dealer’s MENO/MONO may be the same as the firmDesignatedID in the clearing firm’s MEPA/MOPA. In this scenario, the clearing firm would also be required to populate the correspondentCRD and newOrderFDID fields. 

Further, the clearing firm may report the introducing broker-dealer’s customer and account information to CAT on behalf of the introducing broker-dealer. However, since both Industry Members have a separate CAT reporting obligation involving the FDID, each Industry Member must separately register the FDID under their CAT IMID.

Note that it is not required that the clearing firm know the introducing broker-dealer’s FDIDs in which case the firmDesignatedID in the introducing broker-dealer’s MENO/MONO would not be the same as the firmDesignatedID in the clearing firm’s MEPA/MOPA. In this scenario, the clearing firm would also be required to populate the correspondentCRD field.