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Industry Members (other than Small Industry Members) and Small Industry Members that are required to record and report information to FINRA’s Order Audit Trail System pursuant to applicable SRO rules (“Small Industry OATS Reporters”) must report FDIDs for the original receipt or origination of an order that is required to be reported in Phase 2a to the CAT beginning on June 22, 2020. Small Industry Members that are not OATS Reporters must report the FDID when they begin submitting data to CAT on December 13, 2021.

Before the reporting of Customer Account Information and Customer Identifying Information begins in July 2022 regulatory users of the CAT will use FDIDs to identify whether the same account is trading within a single broker-dealer. After the reporting of Customer Account Information and Customer Identifying Information begins, FDIDs will be used to link accounts to specific customers, including mapping accounts with common ownership (for instance, where a customer is associated with more than one FDID).

Phase 2b production readiness testing for Industry Members not submitting equities data in Phase 2a must be completed by July 6, 2020. This deadline, which was previously May 4, 2020, was extended in light of the SEC’s exemptive order, which moved the date by which Industry Members must begin reporting Phase 2b data from May 18, 2020 to July 20, 2020.

Yes. Industry Members are required to complete production readiness testing for Phase 2a reporting by June 8, 2020.  This deadline, which was previously April 6, 2020, was extended in light of the SEC’s exemptive order, which moved the date by which Industry Members must begin reporting Phase 2a data from April 20, 2020 to June 22, 2020.

The reporting of Customer Identifying Information and Customer Account Information consists of two phases, an earlier phase in which Industry Members must report to the CAT certain account information regarding account holders with a Large Trader Identification (LTID) number or an Unidentified Large Trader Identification (ULTID) number pursuant to SEC Rule 13h-1 (collectively called “LTID Account Information”), and a later phase that requires Industry Members to report all Customer Identifying Information and Customer Account Information.

On Wednesday, May 20, 2020 at 2:30 pm ET, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host an industry webinar focusing on Intrafirm Linkage.

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.

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.

Industry Members are only required to report LTIDs for active accounts. That is, accounts for which there is CAT reportable activity.