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search results for “Cais"
- FAQQ62. Since clearing firms rely on their correspondent firms to provide Customer information required for CAIS reporting, can a clearing firm, reporting its version of a Customer on an FDID record, replicate the attribute value for certain required data elements as provided by its correspondent firm?Yes. When reporting its version of the Customer Record, the clearing firm may replicate the attribute value for certain required data elements as provided by its correspondent firm. Specifically, when the correspondentCRD field is populated, the clearing firm may report a role of ‘AUTHREP’ for an…
- FAQT7. Clarifications to the descriptions of the ‘AUTHREP’ and ‘AUTH3RD’ values for the role field were published in version 2.0 r8 of the CAT Reporting Customer and Account Technical Specifications for Industry Members-Full CAIS (“Technical Specifications”) on April 8, 2022. The revised descriptions will require a change to the value my firm must populate in the role field. Given the time constraints between publication and the Production Readiness Certification Deadline for Full CAIS (July 25, 2022), is my firm required to change the ‘AUTH3RD’ value to ‘AUTHREP’ for FDID Records my firm intended to use to conduct testing for production readiness for Full CAIS reporting?No. If an Industry Member or CAT Reporting Agent coded a role of ‘AUTH3RD’ for the scenario where the reporting Industry Member itself has authority to place orders for the Account without prior approval of the account holder(s) and is not the holder of the account, the Industry Member and/or its…
- FAQQ61. Must the Industry Member be identified as a CAT Customer on the related FDID Record in CAIS when there are standing instructions on the Customer’s account, when the Industry Member originates an order in a Customer’s account to satisfy a legal requirement or SEC/SRO rule or when the Industry Member liquidates fractional shares held in a Customer’s account to facilitate operational processes?Whether the Industry Member should be identified as a CAT Customer on the FDID Record depends on whether the Industry Member is an account holder or has authority to place orders for the account without prior approval of the account holder(s). Absent this authority from the account holder(s) (and…
- FAQQ54. Starting with the implementation of Phase 2e (Full CAIS), Industry Members must report one mailing address associated to the FDID in the ‘ADDRESS1’ value of the addrType field. If an FDID is based on a relationship that represents multiple customers with different addresses, and the Industry Member does not store an address for the relationship, but maintains the addresses at the customer level, what address should the Industry Member report to CAIS for ‘ADDRESS1’?If no address is stored at the FDID level, the Industry Member must choose one mailing address associated with one customer and report it as the mailing address associated to the FDID. Industry Members have the ability to report an additional three addresses associated with the FDID via the ‘…
- FAQQ58. To facilitate reporting of correct Customer names as required by the CAT NMS Plan, the Full CAIS Technical Specifications require Natural Person first and last names to be reported in two separate fields. Accordingly, if both the firstName and lastName fields for Natural Person Customers are not populated, the Customer Record will be rejected. The Plan Participants understand that some Industry Members have historically maintained the first and last names in a single field within their system and may be unable to parse them into separate fields by the implementation schedule set forth in CAT Alerts 2022-01 and 2023-01. How must Industry Members report Natural Person Customers if the first and last names are not able to be parsed within the Industry Member’s system by the time the Customer Record is required to be reported to CAIS ?As noted above, the Full CAIS Technical Specifications require the Natural Person first and last names be reported in two separate fields. In the scenario where the Industry Member has historically maintained the Customer name in an unparsed state and will not be able to complete parsing of all…
- FAQQ68. How must Industry Members report an FDID Record to CAIS in the scenario where the Authorized Trader is a government employee of a U.S. state, county or municipality and acting in the capacity of a guardian or conservator for a minor or incapacitated person, and the government employee Authorized Trader does not provide a year of birth or Input Identifier (such as a social security number) citing exemptions from the definition of “customer” under the Customer Identification Program (“CIP”) Rules?In this situation, the minor or incapacitated person must be reported to CAIS with a role of ‘TRDHOLDER’ with the doingBusinessAs field populated with the value of ‘PUBLIC ADMINISTRATOR’. The Authorized Traders Names List must be included with the submission, and include the name of the government…
- FAQQ69. How must Industry Members report an FDID Record to CAIS when a disregarded entity and its parent company have the same Employer Identification Number (EIN) and are both CAT Customers associated to the same FDID? Does the reporting requirement change if the disregarded entity has a different EIN from its parent company?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 EIN to the same FDID will result in a rejection. A disregarded entity is an entity…
- FAQQ16. Can an Industry Member submit the same CAIS record every business day? Or should the Industry Member submit only a delta record? For example, if a record is submitted on T and nothing changes, can the same record be submitted on T+1, T+2, etc.? Or should the Industry Member only resubmit the record if a required data element changes?Industry Members may resubmit the same record each business day but are not required to. If an Industry Member resubmits an identical record to one that already exists in CAT CAIS, CAT CAIS will overwrite the previous record with the new record with the same information. For the LTID Phase…
- FAQQ60. If an Industry Member has received a “Not Held” order, which only gives the Industry Member discretion as to the price and time of execution of the order, must the Industry Member be identified as a CAT Customer on the related FDID Record in CAIS?Whether the Industry Member should be identified as a CAT Customer depends on whether the Industry Member is an account holder or has authority to place orders for the account without prior approval of the account holder(s). Absent this authority from the account holder(s) (and assuming the…
- FAQQ63. How must an FDID Record be reported to CAIS when the account holder is a foreign trust or foreign estate where an allowable Input Identifier value does not exist because the foreign country or foreign municipality does not require or issue any kind of identifier for the foreign trust or foreign estate, and no such other allowable Input Identifier exists? For example, the foreign trust or foreign estate has no associated Legal Entity Identifier (LEI), and is also not assigned any National Registration or Tax Identifier, or any other governmental-issued identifier by a non-national level government body or agency, such as a corporate registry.In limited circumstances where a Legal Entity meets the following criteria: Foreign trust or foreign estate; and No allowable Input Identifier exists because the foreign country or foreign municipality does not require or issue any kind of identifier; and no LEI is assigned to the entity…