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An Industry Member is required to report an LEI for a Customer that is a legal entity to the CAT if the Industry Member has an LEI for a Customer. The CAT NMS Plan does not require a Customer to obtain an LEI if it does not have one, it does not require a Customer to provide an LEI to an Industry Member; and it does not require the Industry Member to request an LEI of its Customer.

As a general rule, the party who applies the default or implicit handling instruction to the order is required to report any material terms in that instruction to CAT.

Some examples:  

The CAT NMS Plan requires Industry Members to “submit to the Central Repository” information  “including CRD number and LEI, if such LEI has been obtained.” “Central Repository” means the repository responsible for the receipt, consolidation, and retention of all information reported to the CAT pursuant to SEC Rule 613 and this Agreement. 
 

The CAT NMS Plan requires Industry Members to “submit to the Central Repository” information  “including CRD number and LEI, if such LEI has been obtained.” “Central Repository” means the repository responsible for the receipt, consolidation, and retention of all information reported to the CAT pursuant to SEC Rule 613 and this Agreement. 
 
The CAT NMS Plan requirement does not require Industry Members to obtain an LEI, but rather to provide its LEI to the Plan Processor (FINRA CAT) if the Industry Member does have an LEI. 

Yes, for each order, the “material terms of the order” (as that term is defined in SEC Rule 613(j)(7)), including those material terms that may be defaulted at a port or connection level, must be reported to CAT. This includes implicit or default instructions agreed to between the Industry Member and its customer or client that are material terms.

On Wednesday, October 21, 2020 at 4:15 pm ET, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host an industry webinar with a specific focus on Industry Members serving as an outbound router on behalf of an NMS Exchange.

In Phase 2a, if an order is received or originated with instructions to work the order using a Trading Algorithm as defined by FINRA Rule 1220(b)(4)(a), a handlingInstructions value of “ALG” should be populated on the New Order or Order Accepted event submitted to CAT along with any additional relevant handlingInstructions.

Consolidated Audit Trail, LLC and FINRA CAT, LLC will host Weekly Industry Testing Checkpoint Calls every Tuesday at 4:15 pm ET beginning on January 7, 2020 until further notice. The events will be held at 4:15 pm ET.

Please note that FINRA CAT, LLC is now utilizing Zoom to conduct industry webinars. Please check your firewall to ensure your firm has the ability to view Zoom content. If you are unable to download and run Zoom, please click the “join from your browser” link. The presentation document and recording will be posted.