FAQs

Yes, market maker quotes are required to be reported to the CAT. Under the CAT NMS Plan, an Options Market Maker’s quotes in Listed Options will be reported to the CAT by the relevant Options Exchange in lieu of reporting by the Options Market Maker. Options Market Makers will not need to separately report these quotes, although they will be required to report to the Options Exchange the time at which a quote in a Listed Option is sent to the Options Exchange (and, if applicable, the time of any subsequent quote modification and/or cancellation where such modification or cancellation is originated by the Options Market Maker). The Options Exchanges are required to report such time information to the CAT in lieu of reporting of such time information by the Options Market Markers to the CAT. Equity market makers, however, are required to report their quotes to the CAT themselves.

Except as otherwise provided, the CAT NMS Plan requires CAT Reporters to report CAT Data to the CAT in milliseconds. To the extent that a CAT Reporter’s order handling or execution systems utilize timestamps in increments finer than milliseconds, then such CAT Reporter is required to utilize such finer increments up to nanoseconds when reporting CAT Data to the CAT.  CAT Reporters that capture timestamps in increments more granular than nanoseconds are required to truncate the timestamps after the nanosecond level--and must not round up or down--for submission to CAT.

No, neither IOIs nor RFQs are reportable to CAT, as neither falls within the definition of an "order" as set forth in the CAT NMS Plan. For CAT purposes, an IOI is a non-firm expression of trading interest that contains one or more of the following elements: security name, side, size, capacity and/or price. 

No. CAT Reporters are not required to record and report information related to non-Eligible Securities to the CAT. CAT Reporters only are required to report information related to Reportable Events in Eligible Securities – that is, NMS Securities and OTC Equity Securities. (See Section 1.1 of the CAT NMS Plan (definition of Eligible Security) available at SEC Approved CAT NMS Plan (11/15/2016))

No, only CAT Reporters that are ATSs are required to submit NBBO information to the CAT. Specifically, ATSs would be required to report certain NBBO information upon the receipt and execution of an order. 

No. CAT Reporters are not required to report to the CAT quotes received via subscriptions to receive market data from market data vendors. Under Sections 6.3(d)(iii) and 6.4(d)(i) of the CAT NMS Plan, CAT Reporters are required to report certain data to the CAT “for the receipt of an order that has been routed.” Although such quotes may fall within the definition of an “order” under the CAT NMS Plan (and SEC Rule 613(j)(8)) as “bids” and “offers,” such quotes have not been routed to the CAT Reporter, and therefore, not subject to the reporting requirement.

This FAQ has been archived and moved to Archived FAQs.

To the extent that any Industry Member’s order handling or execution systems utilize timestamps in increments finer than milliseconds for a given Reportable Event, such Industry Member shall record and report that Reportable Event to the CAT with timestamps in such finer increment up to nanoseconds. To the extent that an Industry Member has order handling or execution systems that utilize timestamps with varying increments, the Industry Member shall use the timestamps associated with each relevant system and Reportable Event when reporting CAT Data to the Central Repository, provided that in all instances such timestamps meet the minimum requirement of one millisecond for non-Manual Order Events.

No. Industry Members only are required to report the “details for each order and each Reportable Event, as applicable,” as set forth in Section 6.3(d) of the CAT NMS Plan, as applied to Industry Members by Section 6.4(d)(i) of the CAT NMS Plan. The definitions of “orders” and “Reportable Events” are set forth in Section 1.1 of the CAT NMS Plan. If a message in an order routing protocol does not meet the definition of an order or a Reportable Event, then details related to that message do not have to be reported to the CAT. For additional information on reporting to the CAT, please see the CAT Reporting Technical Specifications for Industry Members. 

CAT will accept reports involving fractional shares; please refer to the Industry Member Technical Specifications for additional details.

Industry Members will be required to report to the CAT details for each Order and Reportable Event involving an Eligible Security. Under the CAT NMS Plan, “Eligible Security” includes: (1) all NMS Securities, meaning “any security or class of securities for which transaction reports are collected, processed, and made available pursuant to an effective transaction reporting plan, or an effective national market system plan for reporting transactions in Listed Options”; and (2) all OTC Equity Securities, meaning “any equity security, other than an NMS Security, subject to prompt last sale reporting rules of a registered national securities association and reported to one of such association’s equity trade reporting facilities.” While the CAT NMS Plan does not define “prompt last sale reporting rules,” the Operating Committee has determined that transactions in restricted securities (as defined by SEC Rule 144(a)(3)) are not reportable to CAT because they are not subject to prompt last sale reporting rules. However, transactions in direct participation programs (DPPs) must be reported to CAT in Phase 2c of Industry Member reporting. FINRA CAT, LLC, the Plan Processor for the CAT, will publish daily lists of Eligible Securities.

The reporting obligation for the equity legs of complex orders beginning in Phase 2a is as follows. If a complex order includes an equity leg and the terms and conditions of the order are contingent upon the related option trade, the equity leg must be reported using the handlingInstructions value of ‘OPT’ starting in Phase 2a. This reporting obligation applies regardless of whether the complex order is split or not split into components.

Specifically, for a complex order that is routed or received as a complex order and not split into its constituent equity and option legs, the Industry Member must report the equity leg to the CAT in Phase 2a with the ‘OPT’ handlingInstructions value. For a complex order that is routed or received as a complex order and then split into its constituent equity and option legs and routed, the Industry Member must report the equity leg to the CAT in Phase 2a with the ‘OPT’ handlingInstructions value.

In Phases 2a and 2c, if the complex order contains a net price, Industry Members may report the receipt and route of the equity leg as either a market order, or as a limit order with a price of ‘0’ in accordance with FAQ B58 so long as the handlingInstructions field is populated with a value of ‘OPT’ (refer to FAQ E13 for additional information regarding the handlingInstructions requirements on Order Route events for the equity leg of a complex order). In Phases 2a and 2c, CAT will interpret the combination of a market order with a handlingInstructions value of ‘OPT’, or a limit order with a price of ‘0’ and a handlingInstructions value of 'OPT' as an order with a net price. In Phase 2d, a net price will be required. Refer to the Industry Member Reporting Scenarios document for additional information.

Industry Members will be required to report any simple option leg of a complex order in Phase 2b if the complex order has been split and is being worked as individual legs. Industry Members will be required to report complex orders that include both equity and option components to the CAT in Phase 2d. These reporting obligations apply to both FINRA and non-FINRA members that are Industry Members.

Any broker-dealer that is a member of a national securities exchange or FINRA and receives, originates and/or handles orders in NMS Securities, which includes NMS stocks and Listed Options, and/or OTC Equity Securities must report to CAT. There are no exemptions for any such broker-dealer for any reason.

Because the RIA is part of the same legal entity as the US registered broker-dealer, orders received or originated by the RIA are subject to all applicable CAT reporting rules and the US registered broker-dealer must report to CAT all orders that the RIA receives or originates. If the RIA were a separate legal entity that was not a member of a US registered broker-dealer, the RIA would not have an obligation to report orders originated and routed by the RIA to the CAT (also see FAQ B55).

No. The CAT NMS Plan is independent from SEC Rule 17a-3 and does not replace or otherwise alter Rule 17a-3 or any other SEC rules.

Yes. Any broker-dealer that is a member of a national securities exchange or FINRA and receives and/or handles orders in NMS Securities, which includes NMS stocks and Listed Options, and/or OTC Equity Securities – regardless of whether they operate in a foreign country — must report to CAT and satisfy clock synchronization requirements.

No. The CAT NMS Plan does not require CAT Reporters to maintain data submitted to CAT in the CAT format. CAT Reporters are required to retain the data in a format that it could be retrieved and provided to an SRO or the SEC upon request. CAT Reporters are not required to store the data in an electronic system; it could be stored in a manual format.

Market makers are subject to the same reporting requirements as any other Industry Member depending on the type of order received and how it was handled. There are no carve outs or exemptions for orders received or originated by a market maker.

No. An IOC order, by definition, is subject to an immediate partial or full execution. Otherwise, it is automatically partially or fully cancelled. An FOK order, by definition, is subject to either an immediate execution or immediate cancellation. Therefore, it is not necessary to submit to CAT a Cancel Event for an unexecuted order with instructions to be handled as IOC or FOK.

As a general matter, a broker-dealer is considered to be the executing broker in any transaction where its client (either a customer or broker-dealer client) is only able to effect the trade by virtue of the firm’s membership with the applicable market center. Thus, if a client would not be able to effect trades without the firm’s SRO membership, the firm providing the sponsored or direct market access is considered to have received an order from its client and routed it to the market center to which it provides access for the client. Accordingly, such orders must be reported to CAT by the firm providing such access.

When an Exchange for Physical order has been received or originated, a New Order event must be reported with a handlingInstructions value of ‘EW’. If the transaction is affected through an ATS or other crossing system, an Order Route event must be reported by the sender, and an Order Accepted event must be reported by the receiver. If the order is executed via a direct negotiation with the counterparty, the Industry Member must follow the guidance outlined in the Industry Member Scenarios Document for reporting a negotiated trade. If an EFP transaction was originated in response to solicitation, the guidance outlined under B45 would apply.

With respect to the Industry Members’ reporting obligations, when two broker-dealers have entered into a sponsored access agreement whereby one broker-dealer sponsors the other broker-dealer into a specific market center (such as a national securities exchange) by providing use of the sponsoring broker-dealer’s SRO-assigned identifier, both broker-dealers have separate and distinct CAT reporting obligations. For example, if BD A sponsors access into a national securities exchange for BD B, the CAT reporting obligation for each broker-dealer would be as follows:

Sponsored Broker-Dealer BD B (under the SRO-assigned identifier of BDBB)
New Order Event
Order Route Event indicating order was routed to BDA

Sponsoring Broker-Dealer BD A (under the SRO-assigned identifier of BDAA)
Order Accepted Event indicating the order was received from BDBB
Order Route Report indicating order was routed to a national securities exchange

The CAT reporting obligations outlined above are the same regardless of the type of connection used by the sponsored broker-dealer to access the applicable market center. For example, the CAT reporting obligations for each broker-dealer would be the same whether the sponsored broker-dealer used a direct market connection provided by the sponsoring broker-dealer, a third party service provider connection provided by the sponsoring member, or its own proprietary connection to the subject market center.

Industry Members must use the "proxy price" format established by Nasdaq, and not the final trade price, when reporting orders for ETMFs to CAT. 

No. These codes apply to ATSs and are not required to be reported by non-ATSs. However, CAT will not prevent the reporting of such codes by a non-ATS.

Proprietary trading firms are subject to the CAT NMS Plan and SEC Rule 613. As such, proprietary trading firms that originate orders and route them out to other market centers have an obligation to report the origination of the order as a New Order Event (MENO) and the Route of the order as a Route Event (MEOR). Additionally, such firms are required to report any other related events in accordance with the CAT Reporting Technical Specifications for Industry Members.

No.  All CAT Reporters are required to obtain an SRO assigned identifier for the purposes of reporting IMIDs to CAT.

CAT will accept files 24 hours a day, 7 days a week. Reports for events that occur during a particular Trading Day must be reported by 8:00 a.m., ET the following Trading Day or they are marked late by CAT.

All timestamps submitted in STRING format must be reported to CAT in Eastern Time. Timestamps submitted in UTC must not be adjusted for Eastern Time. For additional information, refer to the CAT Reporting Technical Specifications for Industry Members.

An order submitted by a customer who gives the broker discretion as to the price and time of execution is denoted as a "Not Held" order. For CAT, the definition of a "trader" in the context of a "Not Held" order is extended to the broker.

No."DAY" orders that remain unexecuted at the close of a market day are assumed to be canceled and no Cancel Event is required.

Adjustments to orders as the result of a corporate action are not required to be reported to CAT; however, if an order is canceled as a result of a corporate action, you must report the cancellation to CAT via a Cancel Event.

CAT allows for the reporting of fractional shares in decimal format. In this example, the share quantity for the New Order Event should be 100.5, the Order Route Event should be 100, and the share quantity on the Trade Event for the fractional principal execution should be 0.5.

If the Leaves Quantity totals a fractional number of shares, it may be reported in decimal format. For example, a Leaves Quantity of 500-1/2 shares should be reported as “500.5”.

A New Order or Order Accept Event and an Order Canceled Event are required to be reported.

Yes. All proprietary orders originated in the normal course of market making are reportable to CAT.

All prices must be in decimal format. The price fields are 18 numeric characters (including 8 decimal places). A price is not required to contain all 18 characters. In any price, no more than 9 characters can appear without a decimal and no more than 8 characters can appear after the decimal. For example, the following prices are valid: “125”, “000000125”, “000000125.00000000”. Any price that contains more than 18 characters, 9 characters before a decimal, or 8 characters after a decimal will be rejected.

Buy-ins required by SEC or SRO rules (e.g., to comply with the close out requirements of Regulation SHO or FINRA Rule 4320, or the buy-in requirement of SEA Rule 15c3-3) must be reported to CAT using the Buy-In handlingInstructions value (BIN).  

Buy-ins originated pursuant to Regulation SHO or applicable SRO rules (e.g., FINRA Rule 4320), whether executed or unexecuted, must be reported by the clearing firm as a proprietary order of the clearing firm with the FDID of the clearing firm’s proprietary account in which the buy-in originated. The order must be reported with the ‘BIN’ handlingInstructions value to indicate the order represents a buy-in. If the clearing firm allocates the buy-in responsibility to a correspondent broker-dealer pursuant to Regulation SHO or applicable SRO Rules (e.g., FINRA Rule 4320(c)), the correspondent broker-dealer must report the buy-in as a proprietary order with the FDID of the correspondent firm’s proprietary account in which the buy-in occurred. The order must be reported with the 'BIN' handlingInstructions to indicate the order represents a buy-in.
 

No. The changes to Rule 606 do not modify what is reportable to CAT. Under the CAT, broker-dealers must determine whether trading interest falls within the definition of “order” for CAT purposes. As noted in CAT FAQB3, for CAT purposes, an IOI is a non-firm expression of trading interest that contains one or more of the following elements: security name, side, size, capacity and/or price. If trading interest is firm, that trading interest is reportable under CAT (regardless of how it is labeled).

No. Journals and other non-trading, internal position transfers between accounts within the same legal entity generally are not reportable, as they do not involve the receipt or origination of an order or a bid or offer under Rule 613(j)(8), or other Reportable Event. However, position transfers are subject to applicable SRO rules, and if an exchange rule requires a position transfer to be transacted on an exchange, orders originated to effect a transfer and related Reportable Events would be reportable to CAT. In addition, while position transfers within the same entity generally are not reportable to CAT, the origination and internal routing of an order by one part of an Industry Member to a different desk or department for subsequent handling and any related Reportable Events are reportable to CAT.

Under CAT, Industry Members must determine whether trading interest falls within the definition of an “order” for CAT purposes. Specifically, CAT Reporters must consider the definition of an order under Exchange Act Rule 613(j), and any related SEC guidance. As stated in FAQs B3 and B38, non-firm expressions of trading interest that contain one or more of the following elements: security name, side, size, capacity and/or price, are not reportable to CAT. Thus, a key consideration in determining whether trading interest is reportable to CAT is whether it is firm. For example, certain trading interest, sometimes referred to as “conditional orders,” available on some alternative trading systems (ATSs) must have their terms and conditions “firmed up” or otherwise confirmed by the sender before they can be executed against a potential contra-side. Such trading interest would not be reportable to CAT by either the sender or the receiving ATS until it was firmed up/confirmed by the sender. The conditional order becomes reportable once it is firmed up/confirmed and the time of receipt/origination for the sender would be the time the order was firmed up/confirmed by the sender and the time of receipt for the ATS would be the time the ATS receives the firmed up/confirmed order from the sender.

If an Industry Member receives an order and executes the order from the Industry Member’s inventory in one of its proprietary accounts, in whole or in part, rather than through the generation of a proprietary order, the Industry Member will not be required to record and electronically report to the Central Repository the origination of a proprietary order pursuant to Section 6.3(d)(i) as applied to Industry Members by Section 6.4(d)(i). Instead, when the Industry Member reports the execution of the order pursuant to Section 6.3(d)(i)(v) as applied to Industry Members by Section 6.4(d)(i), the Industry Member will record and electronically report to the Central Repository: (1) the Firm Designated ID of the proprietary account; and (2) the account type of the proprietary account. If, however, the Industry Member generates a proprietary order to execute against the order, then the Industry Member would be required to report to the CAT a new order report for the proprietary order.

Industry Members are not required to report an Order Modification Request or Order Cancel Request event to CAT to the extent the order is terminal at the time of the request (i.e., the order has already been fully executed or cancelled) in Phase 2d. This activity may be required in future phases of CAT. 

However, starting in Phase 2d, Industry Members must report a Route Modified (MEMR) or Route Cancelled (MECR) event if the Industry Member modifies or cancels a route. If the route modification or cancellation is rejected by the destination venue, the Industry Member must also populate the routeRejectedFlag with ‘true’. The Industry Member may alternatively report a Route Modified Supplement (MEMRS) or Route Cancelled Supplement (MECRS) event with the routeRejectedFlag populated with ‘true’.

Additionally, if a modification or cancellation request was received that was too late to modify/cancel, and the order was not terminal (e.g., the order was “in-flight” and the sending Industry Member did not receive a modification/cancellation confirmation), the request must be reported as an Order Modification/Cancellation Request event.
 

On June 16, 2025, the SEC approved amendments to the CAT NMS Plan, certain categories of verbal and manual activity are exempt from CAT reporting requirements including: 

(i) until July 31, 2030, floor broker verbal announcements of firm orders on an exchange that are otherwise reported as systematized orders; 

(ii) until July 31, 2030, market maker verbal announcements of firm quotes on an exchange trading floor; 

(iii) telephone discussions between an Industry Member and a client that may involve firm bid and offer communications; and

(iv) unstructured electronic and verbal communications that are not currently captured by Industry Member order management or execution systems (e.g., electronic chats, text messages).

However, certain verbal and manual activity will be required to be reported to CAT, as the SEC’s order expires on July 31, 2030. These activities include: (1) floor broker verbal announcements of firm orders on an exchange that are otherwise reported as systematized orders; (2) market maker verbal announcements of firm quotes on an exchange trading floor. See CAT FAQ C7 for additional information on orders considered “manual” or “electronic” for purposes of reporting to the CAT.

The answer is divided into two sections: one section for verbal or manual bids or offers and one section for electronic bids or offers.

• 1. Verbal and Manual Bids and Offers: As stated in FAQ B43, pursuant to the SEC’s June 16, 2025 order certain verbal and manual activity will be required to be reported to CAT, as this temporary exemptive relief expires on July 31, 2030. See CAT FAQ C7 for additional information on orders considered “manual” or “electronic” for purposes of reporting to the CAT.
   
• 2. Electronic Bids and Offers: Electronic quotes which are provided by or received in a CAT Reporter’s order/quote handling or execution systems in CAT reportable securities and are provided by an Industry Member to other market participants off a national securities exchange are reportable in Phase 2d for both equities and options under these three conditions:
  • a) An equity bid or offer is displayed publicly or has been communicated (1) for listed securities to the Alternative Display Facility (ADF) operated by FINRA; or (2) for unlisted equity securities to an “inter-dealer quotation system” as defined in FINRA Rule 6420(c);
    
    There are a few important notes about quotes in OTC Equity Securities:
    • i. OTC Equity Securities quotes which are received by an Industry Member CAT Reporter operating an inter-dealer quotation system are reportable in Phase 2a by the operator of the inter-dealer quotation system.
    • ii. OTC Equity Securities quotes sent by an Industry Member to an inter-dealer quotation system operated by an Industry Member CAT Reporter are reportable by the Industry Member sending them in Phase 2d.
    • iii. OTC Equity Securities quotes sent by an Industry Member to a quotation venue not operated by an Industry Member CAT Reporter or SRO are reportable in Phase 2a by the Industry Member. Note that as of this writing, the Participants are not aware of the operation of any such quotation venue.
       
  • b) Or, an equity bid or offer which is accessible electronically by customers or other market participants and is immediately actionable for execution or routing; i.e., no further action is required by the market participant providing the quote before a trade or route can occur.
  • c) Or, a listed option bid or offer which is accessible electronically by customers or other market participants and is immediately actionable for routing to another broker-dealer or to an exchange or exchange floor for execution/representation; i.e., no further action is required by the market participant providing the quote before routing to another broker-dealer or an exchange or exchange floor can occur.

Note that as stated in FAQ B6, CAT Reporters are not required to report to the CAT quotes received via subscriptions to receive market data from market data vendors.

Pursuant to the Commission's order granting Exemptive Relief, dated January 23, 2026, all RFQ responses that are communicated in standard electronic format directly to an Industry Member's OMS/EMS or to an RFQ platform and that are not "immediately actionable" (i.e., further action is required before a trade can be executed/routed), to the extent such responses are considered "orders" reportable pursuant to Rule 613(j)(8), are no longer required to be reported to CAT.

As stated in FAQ B44, any equity bid or offer that is accessible electronically by customers or other market participants and is immediately actionable (i.e., no further manual or electronic action is required by the responder providing the quote in order to execute or cause a trade to be executed) is reportable; and any listed option bid or offer which is accessible electronically by customers or other market participants and is immediately actionable (i.e., no further action is required by the responder providing the quote in order to execute or cause a trade to be executed ) is reportable. Accordingly, any response to an RFQ or other form of solicitation response provided in a standard electronic format (i.e. FIX) that meets this definition would be reportable.

Responses communicated in standard electronic format that are immediately actionable are reportable by both the CAT Reporter issuing the RFQ or solicitation (solicitor) and the CAT Reporter responding to the RFQ or solicitation (responder). Specifically, the solicitor must report the receipt of all immediately actionable responses, even those that were not ultimately selected. Non-immediately actionable (NIA) electronic RFQ responses are permanently exempt from CAT reporting.

It is important to note that regardless of the form (electronic or manual) of any RFQ or solicitation response, all orders received or originated as the result of such RFQ or solicitation process must be reported as set forth in the CAT Reporting Technical Specifications for Industry Members. 

Example 1:

A CAT Reporter issues an RFQ through a 3rd party vendor RFQ platform not operated by a broker-dealer. In response to the RFQ, multiple CAT Reporters respond by sending FIX messages directly to the requesting CAT Reporter. Upon selection of a response (either by the trader or automatically by the firm’s trading system), the FIX order from the winning bidder is executed (manually or electronically) OR is routed (manually or electronically) to another broker-dealer or exchange for execution without any further action required by the winning bidder.

The electronically provided responses are reportable by all bidders, even those that were not selected, because the responses are immediately actionable (executable without further action by the responder). Further, the CAT Reporter that issued the RFQ would report the receipt of all immediately actionable responses, as well as any subsequent actions taken to process the order.

Example 2:

A CAT Reporter issues an RFQ and receives several quotes in response through a 3rd party vendor RFQ platform not operated by a broker-dealer. Upon selection of a response, the CAT Reporter either:

• initiates and routes an order electronically to the winning bidder,
• the RFQ platform automatically sends a routed order to the winning bidder, or
• the winning bidder has standing instructions to create a new order acceptance once it receives a message from the RFQ platform that it has won.

The RFQ responses are permanently exempt from CAT reporting because they are not immediately actionable (further action is required by the responder after selection). 

However, the origination of the new order by the solicitor/CAT Reporter, the route of that new order to the winning bidder, and the acceptance of that order by the winning bidder are all reportable events. The solicitor/CAT Reporter would report the new order and route events; the winning bidder would report the order acceptance, as well as any subsequent actions taken to process the order.

Example 3

A CAT Reporter issues an RFQ through a 3rd party vendor RFQ platform not operated by a broker-dealer. In response to the RFQ, multiple CAT Reporters respond by sending FIX messages directly to the requesting CAT Reporter’s OMS. Upon selection of a response, the solicitor CAT Reporter either:

• initiates and routes an order electronically to the winning bidder,
• the RFQ platform automatically sends a routed order to the winning bidder, or
• the winning bidder has standing instructions to create a new order acceptance once it receives a message from the RFQ platform that it has won.

The RFQ responses are permanently exempt from CAT reporting because the CAT Reporters sending the responses would be required to take additional action by accepting a separate order from the requestor before any execution can occur, and would therefore not be considered immediately actionable. 

However, the origination of the new order by the solicitor/CAT Reporter, the route of that new order to the winning bidder, and the acceptance of that order by the winning bidder are all reportable events. The solicitor/CAT Reporter would report the new order and route events; the winning bidder would report the order acceptance, as well as any subsequent actions taken to process the order.

Example 4

An Asset Manager (non-CAT Reporter) issues and receives several quotes in response through a 3rd party vendor RFQ platform that is not part of any CAT Reporter’s OMS/EMS. Upon selection of a response, the Asset Manager either:

• sends a new order request electronically to the winning bidder,
• the RFQ platform automatically sends the new order request to the winning bidder, or
• the winning bidder has standing instructions to create a new order for this Asset Manager once it receives a message from the RFQ platform that it has won.

The RFQ responses are permanently exempt from CAT reporting because they are not immediately actionable. However, the receipt of the order from the Asset Manager, as well as any subsequent actions taken by the winning bidder to process the order are reportable events.

 

This FAQ has been archived and moved to Archived FAQs.

In Phases 2a or 2b, events subsequent to an internal route modification may be populated with any orderID that allows the event to be linked to the order lifecycle. For example, an order that was internally routed from a sales desk to a trading desk is subsequently modified at both the sales and trading desks, and ultimately executed at the trading desk. The sales desk and trading desk maintain different orderIDs. In this example, in Phase 2a the orderID on the related Trade event may link to either the MEIR reported by the trading desk or the MEOM reported by the sales desk. Starting in Phase 2c, the Trade event must link to the MEIM reported by the trading desk.  Additionally, beginning on December 5, 2022, if an order is partially routed internally and a new orderID is not assigned, the deskOrderID field is required to be populated in the Order Internal Modified event (MEIM, MOIM or MLIM). If a new deskOrderID is assigned, the deskOrderID of the event being modified must be reported in the priorDeskOrderID field.

Proprietary equities orders that are simultaneously entered into an OMS/EMS upon origination are always considered electronic. 

This FAQ has been archived and moved to Archived FAQs.

No.  Conversion of convertible bonds into the underlying equity are not orders, as defined by SEC Rule 613. Therefore, such conversions are not required to be reported to CAT.

No.  ETF creations and redemptions are not orders, as defined by SEC Rule 613.  Therefore, ETF creations and redemptions are not required to be reported to CAT.

No. ADR creations and cancellations are not orders, as defined by SEC Rule 613. Therefore, ADR creations and cancellations are not required to be reported to CAT.

No. Transfers of securities during an account transfer between broker-dealers (e.g. ACATS transfers, transferring a Registered Investment Advisor (RIA) book of business from one Industry Member to another Industry Member and for a clearing firm when a correspondent firm changes to another clearing firm) are not orders, as defined by SEC Rule 613. Therefore, such account transfers are not required to be reported as Transaction activity to CAT. The same guidance would apply to a firmDesignatedID (FDID) representing a Relationship ID or Entity ID. 

This FAQ was archived and moved to Archived FAQs.

Since the RIA is placing the order directly in the customer account at BD2, BD2 is required to report a New Order event (“MENO”) with a Firm Designated ID (“FDID”) that represents the customer/client account number. BD2 is also required to report any subsequent actions taken on the order (e.g., executing, routing, canceling, etc.). BD1 does not have an order in this scenario and therefore does not have a CAT reporting obligation.

Industry Members undergoing an organizational change should contact FINRA CAT, LLC to ensure that proper registrations, entitlements and reporting relationships are established in CAT, so that there are no interruptions in the Industry Member’s ability to report to CAT upon the completion of the transaction. Industry Members undergoing organizational changes should also pay particular attention to open limit orders established prior to the completion of any transaction. If the predecessor firm has open limit orders on its books that will be executed or otherwise resolved under the successor firm, the successor firm must populate the originatingIMID field on any events related to a New Order or Order Accept Event originated by the predecessor with the CATReporterIMID of the predecessor firm to support linkage. Industry Members undergoing an organizational change as described above may notify the FINRA CAT Helpdesk at 888-696-3348 or [email protected] prior to the completion of the transaction.

The orderType field for orders received/originated or routed as Stop orders must be populated as ‘MKT’, and the orderType field for orders received/originated or routed as Stop Limit orders must be populated as ‘LMT’. The following chart contains a description and usage examples for the handlingInstructions required for Stop, Stop Limit, Stop on Quote, Stop Limit on Quote, Trailing Stop, and Trailing Stop Limit orders. If the stop price is known (the stop price in these examples is $1.00), then the handling instruction of STOP denotes the stop price and requires a numeric value representing the stop price (e.g., STOP=1.00). In instances where there is a Stop order, but the exact stop price is unknown because it is either based on an underlying condition or will be determined by the destination venue, then the Industry Members may populate a handlingInstructions value of ‘STOPF’ (See FAQ B67).

* If the stop price is not known at the time of order receipt or origination or receipt, Industry Members must populate a handlingInstructions value of STOPF instead of STOP.  All additional required handlingInstructions values outlined above (i.e., SLQ, SOQ) would also be required to be reported in conjunction with STOPF. See FAQ B67 for additional information.

See also:

• See FAQ B66 regarding when the Order Effective event/Option Order Effective event (MEOE/MOOE) is required to be reported to CAT.
• See FAQ B59 for information related to the reporting requirements when a Stop, Stop Limit, Stop on Quote, or Stop Limit on Quote order is triggered.
• See FAQ B60 regarding which party has the obligation to report the Order Effective event/Option Order Effective event (MEOE/MOOE) to CAT.
• See FAQ B61 for information on reporting requirements for Stop Stock orders.
• See FAQ B62 for information related to the reporting requirements for Trailing Stop and Trailing Stop Limit orders.
• See FAQ B67 for information related to Stop orders when the exact stop price is unknown because it is either based on an underlying condition or will be determined by the destination venue.

If an order is received/originated or routed without a specific limit price but includes handlingInstructions that may include certain pricing criteria, such as a ‘PEG’ or options related order, the orderType field may be populated as either ‘MKT’, or ‘LMT’ with a price of ‘0’. The ‘PEG’ or other instruction must be included in the handlingInstructions field on the event. If an order is not a market order but is received or originated without a specific limit price and does not have handlingInstructions that include pricing criteria, such as an order that is originated to represent multiple customer orders but does not have a set limit price, the orderType field must be populated as ‘LMT’ and the price must be ‘0’. 

This guidance does not apply to Stop or Stop Limit orders - refer to FAQ B57 for additional information on the orderType field for Stop, Stop Limit, Stop on Quote, Stop Limit on Quote, Trailing Stop, and Trailing Stop Limit orders.

In Phase 2a (equities) and Phase 2b (options), Industry Members are required to report a New Order event or New Option Order event (MENO or MONO) representing receipt or origination of the order with applicable handlingInstructions, as well as any subsequent actions taken on the order (e.g., executing, routing away or canceling).  

Beginning in Phase 2c (equities) and Phase 2d (options), in addition to reporting the receipt or origination of the order with applicable handlingInstructions, Industry Members will be required to report an Order Effective event or Option Order Effective event (MEOE or MOOE) when all underlying conditions of an order (i.e., the Stop) are met such that the order becomes and remains effective until it is fully executed or cancelled. Refer to the Industry Member Reporting Scenarios document for additional information.

Additionally, beginning December 5, 2022, the Multi-Leg Order Effective event (MLOE) is required to be reported to indicate that a multi-leg order, or an underlying condition of a multi-leg order, has become effective.

See also:  

•    See FAQ B57 regarding how the orderType and handlingInstructions fields must be populated for Stop, Stop Limit, Stop on Quote, Stop Limit on Quote, Trailing Stop, and Trailing Stop Limit orders.
•    See FAQ B60 regarding which party has the obligation to report the Order Effective event/Option Order Effective event/Multi-Leg Order event (MEOE/MOOE/MLOE) to CAT.
•    See FAQ B61 for information on reporting requirements for Stop Stock orders.
•    See FAQ B62 for information related to the reporting requirements for Trailing Stop and Trailing Stop Limit orders.
•    See FAQ B67 for information related to Stop orders when the exact stop price is unknown because it is either based on an underlying condition or will be determined by the destination venue.
 

Beginning in Phase 2c (equities) and Phase 2d (options), the party that is holding the order at the time the order or all underlying conditions are met (such that the order becomes and remains effective until it is fully executed or cancelled) has the obligation to report to CAT the Order Effective event or Option Order Effective event (MEOE or MOOE). Refer to the Industry Member Reporting Scenarios document for additional information.

Additionally, beginning December 5, 2022, the Multi-Leg Order Effective event (MLOE) is required to be reported to indicate that a multi-leg order, or an underlying condition of a multi-leg order, has become effective.

See also:  

•    See FAQ B57 regarding how the orderType and handlingInstructions fields must be populated for Stop, Stop Limit, Stop on Quote, Stop Limit on Quote, Trailing Stop, and Trailing Stop Limit orders.  
•    See FAQ B59 for information related to the reporting requirements when a Stop, Stop Limit, Stop on Quote, or Stop Limit on Quote order is triggered.
•    See FAQ B62 for information related to the reporting requirements for Trailing Stop and Trailing Stop Limit orders.
•    See FAQ B67 for information related to Stop orders when the exact stop price is unknown because it is either based on an underlying condition or will be determined by the destination venue.
 

In Phase 2a, Industry Members are required to report a New Order event (MENO) with a handlingInstructions value of ‘SW’ (Stop Stock Transaction) indicating that the transaction resulted from an order for which a member and another party agreed that the order will be executed at stop stock price or better. The ‘SW’ handlingInstructions must be paired with a numeric value representing the agreed upon stop stock price (e.g., SW=35.00). The Industry Member would also be required to report any subsequent actions taken on the order (e.g., executing, routing away or canceling).

Starting in Phase 2c, Industry Members will still be required to report the ‘SW’ handlingInstructions paired with the stop stock price (e.g., $35.00); however, for Stop Stock orders where the entire shares quantity of the order is not being stopped, then the handlingInstructions field must also be populated with a value of ‘SWQ’ paired with the quantity of shares being stopped (e.g., SWQ=100). When a handlingInstructions value of ‘SWQ’ is populated, the value of ‘SW’ paired with the stop stock price must also be populated, otherwise the record will reject for invalid handlingInstructions.

Refer to the Industry Member Reporting Scenarios document for additional information.
 

For CAT reporting purposes, a Trailing Stop order allows the stop price to increase (or decrease) by a predetermined amount or formula (e.g., a specified dollar amount, a percentage of the market price, or some other predetermined criteria) as the market price of the security advances (or declines). Once the Trailing Stop price is triggered, the sell (or buy) order becomes either an executable market order or a limit order (e.g., a Trailing Stop Limit order). 

In Phase 2a/2b, Industry Members are required to report a New Order event or New Option Order event (MENO or MONO) with a handlingInstructions value of ‘TS’ (Trailing Stop) representing receipt or origination of the Trailing Stop order. When the market price hits or goes through the highest (or lowest) calculated Trailing Stop Price, Industry Members are also required to report an Order Modified event or Option Order Modified event (MEOM or MOOM) with applicable updates to the price field. The MEOM/MOOM must not have a handlingInstructions value of ‘TS’ since the underlying condition of the order was triggered and the order is no longer a Trailing Stop order. Industry Members are not required to report additional MEOM/MOOM events each time the predetermined amount or formula is recalculated. The Industry Member is also required to report any subsequent actions taken on the order (e.g., executing, routing away or canceling). 

In Phase 2c (equities) and Phase 2d (options), Industry Members will still be required to report a New Order event or New Option Order event (MENO or MONO) with a handlingInstructions value of ‘TS’ representing receipt or origination of the Trailing Stop order. Industry Members will also be required to report an Order Effective event or Option Order Effective event (MEOE or MOOE) when all underlying conditions (i.e., the Trailing Stop) are met and the order becomes and remains effective instead of an MEOM/MOOM (as required in Phase 2a/Phase 2b). Additionally, beginning December 5, 2022, the Multi-Leg Order Effective event (MLOE) is required to be reported to indicate that a multi-leg order, or an underlying condition of a multi-leg order, has become effective. The triggerPrice field on the MEOE/MOOE/MLOE event must be populated at the highest (or lowest) calculated trailing stop price. Refer to the Industry Member Reporting Scenarios document for additional information.

See also:  

•    See FAQ B57 regarding how the orderType and handlingInstructions fields must be populated for Trailing Stop and Trailing Stop Limit orders.
•    See FAQ B60 regarding which party has the obligation to report the Order Effective event/Option Order Effective event/Multi-Leg Order Effective event (MEOE/MOOE/MLOE) to CAT.
•    See FAQ B63 for information on how the initiator field should be populated if an Industry Member modifies or cancels an order based on implicit customer instructions communicated with the order.
 

In an Order Modified and Cancel/Replace event (MEOM), the initiator field indicates who initiated the order modification. In an Order Cancelled event (MEOC), the initiator field indicates who initiated the order cancellation. If an implicit, unsolicited modification or cancellation action is taken by an Industry Member based on inferred customer instructions (e.g., Industry Member cancels an order associated with a particular ATS Order Type that articulates an expiry time), then the initiator field must be populated with a value of ‘F’ (Initiated by the firm).

Similarly, for actions initiated by the Industry Member unilaterally as a direct result of customer modifications or cancellations, such the cancellation of a representative order following the customer’s cancellation of the associated client order held at the firm, or the modification of an Internal Route following the customer’s modification of the associated client order held at the firm, then the initiator field must likewise be populated with a value of ‘F’ (Initiated by the firm). 

• For example, a customer requests that Industry Member Broker 1 cancel an order for which Broker 1 had previously generated an associated representative order. While the Order Cancelled event (MEOC) associated with the client order held at Broker 1 would be denoted with ‘C’ (as the cancellation was initiated by the customer), the cancellation of the corresponding representative order by Broker 1 would be denoted with ‘F’, as the cancellation was initiated by the Industry Member.

The same guidance applies for Trailing Stop and Trailing Stop Limit orders routed between Industry Members in Phase 2a. For example, Industry Member Broker 1 originates a Trailing Stop order, which is then routed to and accepted by Market Maker 2. Market Maker 2 monitors the market conditions and is holding the order at the time the market price hits or goes through the highest (or lowest) calculated Trailing Stop Price, at which point Market Maker 2 unilaterally routes the order to an exchange for execution based on the implicit instructions communicated with the Trailing Stop order upon receipt. In this example, Market Maker 2 reports the triggering event in Phase 2a via an MEOM event, with the initiator flag populated with ‘F’, and the receiverIMID, senderIMID, senderType, routedOrderID left blank, as Broker 1 did not communicate modification instructions to Market Maker 2 at the time of trigger. Note, reporting requirements for Trailing Stop orders change in Phase 2c (see FAQ B62).

No. A single Order Fulfillment reflecting the final average price fill to the client order is required.  A Fulfillment Amendment would only be appropriate if the fill to the client was changed after the final fulfillment had been provided to the client. Some systems may provide intraday transparency to the progress of executing an order as informal information that is not considered by the firm to be ‘final’ fulfillments, and these should not be reported to CAT as fulfillments and fulfillment amendments.

This FAQ was moved. See FAQ E31.

Beginning in Phase 2c (equities) and Phase 2d (options), the Order Effective event/Option Order Effective event (MEOE/MOOE) is required to be reported to CAT when all underlying conditions of an order are met such that the order becomes and remains effective until it is fully executed or cancelled. Examples of orders requiring the MEOE/MOOE event include:

• Stop, Stop Limit, Stop on Quote, Stop Limit on Quote, Trailing Stop, and Trailing Stop Limit orders. 
• Conditional Orders wherein an order is contingent on the execution of another order.
• Orders contingent on the occurrence of a market condition (e.g., once symbol ABCD trades X# of shares, the order becomes executable).

In all of the above examples, one and only one MEOE/MOOE would be reported by the Industry Member holding the order at the time all underlying conditions are met (i.e., the stop).

The MEOE/MOOE should not be used in instances when an order has conditions that can become activated and inactivated multiple times throughout the day. Examples of the types of orders where the MEOE/MOOE should not be used include:

• Orders originated or generated utilizing a specific Trading Algorithm, as defined in the Industry Member Technical Specifications, that may cause it to move in and out of specific conditions or parameters. 
• Orders with spread conditions. For example, an Industry Member receives or originates Order A to purchase 200,000 shares of XYZ with the instructions that the order only be acted upon when the market price of security XYZ is within a $10.00 spread from the price of security ABC. 

In both of the above examples, Industry Members would not report an MEOE/MOOE event. 

See also:

• See FAQ B57 regarding how the orderType and handlingInstructions fields must be populated for Stop, Stop Limit, Stop on Quote, Stop Limit on Quote, Trailing Stop, and Trailing Stop Limit orders.  
• See FAQ B59 for information related to the reporting requirements when a Stop, Stop Limit, Stop on Quote, or Stop Limit on Quote order is triggered.
• See FAQ B60 regarding which party has the obligation to report the Order Effective event/Option Order Effective event (MEOE/MOOE) to CAT.
• See FAQ B62 for information related to the reporting requirements for Trailing Stop and Trailing Stop Limit orders.
• See FAQ B67 for information related to Stop orders when the exact stop price is unknown because it is either based on an underlying condition or will be determined by the destination venue.
• See FAQ D26 regarding ‘CND’ and ‘CMC’ handlingInstructions.

B57 and the Stop Orders section of Industry Member Technical Specifications note that the handling instruction of ‘STOP’ denotes the stop price and requires a numeric value representing the stop price (e.g., STOP=1.00). In instances where it is known that the order is a stop order, but the exact stop price is unknown because it is either based on an underlying condition or will be determined by the destination venue, Industry Members may populate a handlingInstructions value of ‘STOPF’.
 
Starting in Phase 2c (equities) and 2d (options), in scenarios where the trigger price was not explicitly captured in the handlingInstructions field on the related new order or in order accepted events (e.g. Stop Formula, Trailing Stop), then the triggerPrice field must be populated on the Order Effective event/Option Order Effective event (MEOE or MOOE) to reflect the stop price.  

Example 1: 
Conditional Order A is originated by Industry Member Broker 1 specifying that a stop price be calculated only after Order B is executed.  In this example, Broker 1 reports a New Order event (MENO) event with the ‘STOPF’ and ‘CND’ handlingInstructions values. Broker 2 is holding the order at the time all underlying conditions of the order (Order B being executed and then the triggering of the Stop) are met, at which point Broker 1 would report an MEOE event with the stop price in the triggerPrice field.

Example 2:
A stop order is originated by Industry Member Broker 1 and routed to Industry Member Broker 2 with instructions communicated that the stop price be set at Ask-5 (Ask minus $5.00). Broker 1 relies on Broker 2 to calculate the stop price. Upon order acceptance, Broker 2 uses its market data feeds to determine that $5.00 from the current market price of the security is $10.00. In this example, Broker 1 reports a New Order event (MENO) event with the ‘STOPF’ handlingInstructions value, and Broker 2 would report an Order Accepted event (MEOA) with the stop price determined by Broker 2 upon acceptance of the order (e.g., STOP=10.00). Broker 2 is holding the order at the time the stop was triggered and (starting in Phase 2c) reports the MEOE event. Since the stop price was captured on the MEOA event, the MEOE event does not require a triggerPrice.

See also:

• See FAQ B57 regarding how the orderType and handlingInstructions fields must be populated for Stop, Stop Limit, Stop on Quote, Stop Limit on Quote, Trailing Stop, and Trailing Stop Limit orders.  
• See FAQ B59 for information related to the reporting requirements when a Stop, Stop Limit, Stop on Quote, or Stop Limit on Quote order is triggered.
• See FAQ B60 regarding which party has the obligation to report the Order Effective event/Option Order Effective event (MEOE/MOOE) to CAT.
• See FAQ B62 for information related to the reporting requirements for Trailing Stop and Trailing Stop Limit orders.
• See FAQ B66 regarding when the Order Effective event/Option Order Effective event (MEOE/MOOE) is required to be reported to CAT.
• See FAQ B67 for information related to Stop orders when the exact stop price is unknown because it is either based on an underlying condition or will be determined by the destination venue.
• See FAQ D26 regarding ‘CND’ and ‘CMC’ handlingInstructions.
   

For order events (new order, new quote, trade and fulfillment events), if an Industry Member uses the same account for both market making and non-market making proprietary activity, the accountHolderType must be populated on an order-by-order basis. Orders meeting the definition of market making activity pursuant to FAQ C5 should be reported with the accountHolderType of 'O'. All other orders must be reported with the accountHolderType of 'P'.

Per FAQ U5, allocations to firm owned or controlled accounts are not required to be reported but may optionally be reported. For allocation events (post-trade allocation and amended allocation events) that are being optionally reported, if the Industry Member’s system is able to determine the accountHolderType on an allocation-by-allocation basis, the same guidance applies: allocations related to orders meeting the definition of market making activity pursuant to FAQ C5 should be reported with the accountHolderType of 'O' and allocations related to all other orders must be reported with the accountHolderType of 'P'. However, if the Industry Member’s system is unable to determine if the allocation is related to an order that was market making or non-market making proprietary activity, the Industry Member must populate the accountHolderType on its allocation events with the allowable value ('P' or 'O') according to its books and records. 

For NAVs with no offset, if the calculated NAV price is not known until after 4:15:00 pm ET on the date of origination/receipt, the MENO/MEOA should be marked as a market order, or as a limit order with a price of ‘0’, and handlingInstructions of ‘NAV'. Beginning in Phase 2d, for NAVs with an offset, the MENO/MEOA should also be marked with the handlingInstructions of ‘OFF’. The eventTimestamp on the MENO/MEOA should reflect the date and time that the terms and conditions of the order (with the exception of the calculated NAV) were recorded in the firm’s books and records. 

The MENO/MEOA must be reported to CAT by 8 am ET on T+1, where T represents the CAT Trading Day that the order was originated/received.  

For guidance on reporting price on order events in ETMFs or “NextShares,” see FAQ B23.
 

For NAVs, the eventTimestamp on the MEOT should reflect the date and time of execution of the trade at the calculated NAV and should match the date and time of execution reported in the trade report submitted to the FINRA trade reporting facility. The price should be the calculated NAV.

The MEOT must be reported to CAT by 8 am ET on T+1, where T represents the CAT Trading Day that the order was executed. For example, if the NAV is determined after 4:15:00 pm ET on Monday and the order is executed at that time, the MEOT must be reported to CAT by 8 am ET on Wednesday. 
 

If an equity order is tied to stock, fixed income, futures, or another product that is not reportable to CAT at a net price (or other formula such as a specific delta no later than Phase 2d), Industry Members must populate the appropriate handlingInstructions value of ‘TTS’, ‘TTF’, ‘TTO’, ‘TTU’, or ‘FUT’. This activity does not meet the definition of a multi-leg order, as these trading strategies do not contain an option leg, and must continue to be reported to CAT as equity order events in Phase 2d.

If a simple equity is tied to a simple option at a net price (or other formula such as a specific delta no later than Phase 2d) as part of a pairs trading strategy that does not meet the definition of a multi-leg order, the equity order must contain a handlingInstructions value of ‘TTSO’, and the option must contain a handlingInstructions value of ‘TTS’.

The equity leg of a multi-leg order is reportable in Phase 2a/2b/2c, and must include the handlingInstructions value of 'OPT', as outlined in FAQ B12. This activity will be reported to CAT as multi-leg order events in Phase 2d, and the handlingInstructions values ‘OPT’ and ‘TTSO’ will not be required to be captured on multi-leg order events. 

If a single, simple option order is tied to futures, fixed income, or another product that is not reportable to CAT, Industry Members must populate the appropriate handlingInstructions values of ‘TTF’, ‘TTO’, or ‘FUT’ in Phase 2b.

If an option order is tied to stock and meets the definition of a multi-leg order, Industry Members will be required to report this activity to CAT in Phase 2d. The handlingInstructions value of ‘TTS’ will not be required to be captured on multi-leg order events. 

While this multi-leg activity may be optionally reported to CAT beginning in Phase 2b, the option legs must be reported as simple option events with a handlingInstructions value of ‘CMPX’.  The handlingInstructions value of ‘TTS’ is not required. 

Beginning in Phase 2d, Industry Members will be required to populate the netPrice field on equity or simple option order events with the net price of the order if the order is tied to stock, fixed income, futures, or another product that is not reportable to CAT at a net price. The netPrice field will not be required if the order is tied to stock, fixed income, futures, or another product that is not reportable to CAT with another formula such as a specific delta.
 

No. In Phase 2a/2b, any response to an RFQ or other solicitation process is not required to be reported as a MENO or MONO no matter the method of response (electronic or manual).  In addition, while the Responder is not required to report its response to CAT, it may optionally do so using the handlingInstructions value of ‘SR’ on the appropriate CAT events.

However, once a winning bid(s) has been selected, any subsequent reportable activity must be reported to CAT.  For example, if the Solicitor must send an order to the Responder, then both the Solicitor and Responder have CAT reporting obligations. 

The reporting requirements for Phases 2c and 2d are different. Please refer to FAQ B45 for more details. 

In a scenario where a customer order is received and executed, and an Industry Member makes an accommodation to the customer due to a customer error (such as an incorrect quantity entered), Industry Members must report to CAT in accordance with what is captured in their books and records. 

For example, if the firm’s books and records reflect the accommodation as a correction to the order, the accommodation must be reported to CAT as an order correction event (actionType value of ‘COR’) with a handlingInstructions value of ‘CAC’ (Customer Accommodation Correction). If the firm’s books and records reflect the accommodation as a modification to the order, the accommodation must be reported to CAT as an Order Modified event. If the firm’s books and records reflect the accommodation only as a correction to the trade, no order correction event or Order Modified event is required, and the Industry Member is only required to report the trade correction as outlined in FAQ E29.
 

If an issue symbol is delisted and is no longer tradable on any market because the security is no longer valid, then no MEOC is required for GTC orders in that symbol, as this scenario would be considered an implicit cancellation. Industry Members choosing to optionally report this activity should be mindful that any errors received as a result of the symbol having been delisted on the Event Date would not be repairable.

Similarly, if a corporate action (e.g., merger/acquisition) occurs in which a security is no longer valid, and the symbol becomes associated with a new security, no MEOC would be required for the original security. For example, if there is an open GTC order in symbol ABC and ABC is acquired and no longer trades on any market, no MEOC is required.

However, explicit cancellations are required for any cancelled GTC orders and are reportable using the symbol on the list in the following scenarios. 

•    If the issue symbol changed and there is no change to the underlying security. For example, if a security trades under symbol ABC and changes its symbol to XYZ.  A cancel event is not required for ABC (the original order) but would be required for the new symbol, XYZ.

•    The symbol was delisted from one market and continued to trade on another market (either under the same symbol or a different symbol). For example, ABC traded over-the-counter and then listed on an Exchange under a new symbol XYZ.  A cancel event is not required for ABC (the original order) but would be required for the new symbol, XYZ.

Industry Members are responsible for identifying material changes to an underlying security from corporate action announcements and taking appropriate action to ensure compliance with their books and records and CAT transaction reporting requirements.

No. Starting in Phase 2d, Industry Members must capture and report the date and time they received a request from a customer or another Industry Member to modify or cancel an order in the requestTimestamp field. This requirement is also applicable to requests received from an internal desk to modify/cancel an existing order. The requestTimestamp is not required on modify/cancel events initiated by the firm or by a receiving desk but can be optionally reported. 

Industry Members may report the requestTimestamp by either capturing it in the modify/cancel event or by capturing it in a separate modify/cancel request event. If the Industry Member is able to capture the requestTimestamp in the modify/cancel event, a separate modify/cancel request event must not be reported.

Example 1 (requestTimestamp required)

Industry Member receives request to modify order from a customer. The firm must capture time the request was received from the customer.

Example 2 (requestTimestamp required)

Desk 2 receives a request to modify from Desk 1 who originally routed the order. Desk 2 must capture the time the request to modify was received from Desk 1. 

Example 3 (requestTimestamp NOT required)

Desk 2 receives an order from Desk 1. Desk 2, at some point thereafter, modifies the order. Desk 2 is not required to capture and report a request time. 

Example 4 (requestTimestamp NOT required)

Industry Member modifies a firm initiated order. Industry Member is not required to capture and report the request time.

A mass cancellation is any process by which an execution venue (such as an ATS or exchange) automatically cancels all open orders or a group of open orders resulting from the receipt of a single mass cancellation message, whether communicated electronically or manually. Industry Members are not required, but may optionally choose, to report Route Cancelled events to CAT resulting from a mass cancellation message if the execution venue receiving the mass cancellation instruction is a CAT Reporter. If the mass cancellation instruction is sent to a foreign destination or other destination that is not a CAT Reporter, the Industry Member must report the Route Cancelled events to CAT.

All orders routed to an execution venue and subsequently cancelled by the sender without the use of a mass cancellation message/instruction must be reported to CAT as individual Route Cancelled events. 

Example 1: Exchange Member 1 routed orders to Exchange A on session EX1 and Exchange A accepted them all. Due to a connectivity issue, Exchange Member 1 must call Exchange A to cancel all open orders routed on session EX1. Exchange A verifies verbally that all orders on this session are cancelled but Exchange Member 1’s OMS cannot generate Route Cancelled events for the non-electronic/manual mass cancellation. Exchange Member 1 is not required to report Route Cancelled events in this case.

Example 2: Exchange Member 1 routed orders to Exchange A on session EX1 and Exchange A accepted them all. For expediency, Exchange Member 1 sends an electronic mass cancel request to Exchange A to cancel all open orders routed on session EX1. Exchange A electronically cancels all open orders on this session. Exchange Member 1 is not required to report Route Cancelled events in this case.

Example 3: US Broker-Dealer 2 routed orders to Foreign Exchange B on session EX2 and Exchange B accepted them all. For expediency, Broker Dealer 2 sends an electronic mass cancel request to Foreign Exchange B to cancel all open orders routed on session EX2. Foreign Exchange B electronically cancels all open orders on this session. In this case, Broker Dealer 2 is required to report all Route Cancelled events in CAT reportable symbols.
 

Subsequent events (for example, MEOM, MEOC) for any open orders in the original security prior to the corporate action are not required to be reported and if reported, will result in a linkage error that cannot be repaired. 

If the customer/client wants to trade in the new security, the Industry Member must create a new order for the issue symbol with a new orderID.

Industry Members are responsible for identifying material changes to an underlying security from corporate action announcements and taking appropriate action to ensure compliance with their books and records and CAT transaction reporting requirements.