Q. Customer and Account Information
This topic includes information related to the requirements for reporting customer and account data to the CAT.
- FAQQ33. May an Industry Member leverage a previously established Reporting Relationship for CAIS? For example, if an Industry Member has already authorized a submitter to report transaction data to CAT, must that Industry Member also authorize the same submitter to report data to CAIS?
Because all CAIS data is maintained separately from transaction data for data security reasons, Industry Members are required to establish separate Reporting Relationships for CAIS. It is acceptable to have relationships with the same party for both CAT transaction data and CAIS; however they are separate relationships and will need to be separately established. CAT CAIS Reporting Relationships must be established to authorize another CAT Reporting Agent to submit on a firm’s behalf. Relationships must be established prior to any data submissions to the CAT CAIS Reporter Portal.
Yes, Production data may be submitted to the CAIS Test environment. Optionally, data submitted to the CAIS Test environment can be obfuscated; however it is not required. For more information on testing in the CAT CAIS Test environment, see Section 7 of the CAT CAIS Specifications.
- FAQQ37. How do the CAT reporting requirements for Large Trader IDs (LTIDs) and Legal Entity Identifiers (LEIs) differ?
As explained in FAQs Q6 and Q31, CAT Reporters are required to obtain and report LTIDs to CAT, including introducing brokers and executing brokers that use separate clearing brokers. In contrast, Legal Entity Identifiers (LEIs) are not required to be disclosed to a broker-dealer, nor is a broker-dealer required to obtain an LEI from its customers. Further, there are no obligations imposed by SEC Rule 613 or the CAT NMS Plan to obtain an LEI from a customer for purposes of reporting it to CAT.
- Reference Material
There is no record limit for files submitted to CAT CAIS through SFTP. However, files submitted through SFTP are limited to a maximum uncompressed size of 100GB. Files sizes <= 1GB are recommended as feedback will be returned faster. For more information, see CAIS Technical Specification section 5.1.3 – Data File Submission. Note that the file size recommendations for CAT CAIS are different from the file size recommendations for CAT Transaction reporting.
- Technical Specifications
- FAQQ35. Where can Industry Members find information regarding production readiness testing requirements for CAT CAIS?
The requirements are detailed in the CAT CAIS Industry Member Onboarding Guide.
LTID identifiers are issued by the SEC. These are not publicly available.
Consolidated Audit Trail, LLC and FINRA CAT, LLC will host Biweekly Industry Testing Checkpoint Calls for CAIS/LTID every other Wednesday 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.Audio file
- FAQQ6. Are Industry Members required to report large trader identifiers (“LTIDs”) to the CAT and, if so, when?
Industry Members are required to obtain and report LTIDs to CAT for Firm Designated IDs (FDID) with Reportable Events that must be reported to CAT in Phase 2c (equities) and Phase 2d (options). This applies to both existing FDIDs and new FDIDs established after the Phase 2c and 2d implementation dates. Each Industry Member must determine how to obtain the LTID for each FDID – to the extent that an LTID exists – in order to report this information to CAT.