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Q. Customer and Account Information
This topic includes information related to the requirements for reporting customer and account data to the CAT.
On Thursday, July 9, 2020 at 11 am ET, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host an industry webinar to highlight the customer and account reporting requirements of the CAT NMS Plan and give an overview of the CAT Reporting Customer and Account Technical Specifications for Industry Members-CCID DRAFT v2.0.Audio file
- FAQQ3. When must Industry Members submit Customer Account Information and Customer Identifying Information to the CAT?
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.
- FAQQ13. How should an Industry Member populate the ltidEffectiveDate if it did not record the date on which the LTID or ULTID became associated to the FDID within its systems?
Industry Members must record in their systems the date that an LTID or ULTID becomes associated with an FDID (“LTID Effective Date”). Some Industry Members may have to change current onboarding activities to ensure this information is obtained and recorded.
If an Industry Member has not recorded the LTID Effective Date, they may use the go-live date as the ltidEffectiveDate until the go-live date. Starting on the go-live date, Industry Members must record and report an accurate LTID Effective Date.
Industry Members should make an effort to obtain an accurate reason as to why the LTID or ULTID is no longer associated to the FDID.
- FAQQ17. Are Industry Members required to report LTIDs for dormant or inactive accounts? For example, an Industry Member has a customer that qualifies as a Large Trader but that customer has not had any account activity for several months.
Industry Members are only required to report LTIDs for active accounts. That is, accounts for which there is CAT reportable activity.
The ltidEndDate is the date the Industry Member became aware that the LTID or ULTID was no longer associated with the FDID.
- 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. Once a record has been received by CAT CAIS, Industry Members are only required to submit changes or corrections to required data elements.
- FAQQ10. Is the ltidEffectiveDate the date when the LTID was assigned by the SEC or the date that the clearing firm was provided the LTID?
The ltidEffectiveDate in this scenario is the date the Industry Member was provided the LTID and it was associated with the account.
- FAQQ15. If an Industry Member ends an LTID to FDID association for a legitimate reason (such as the customer no longer qualified as a large trader), and later is required to reestablish it, what should the ltidEffectiveDate be?
If an LTID to FDID association is ended for a legitimate reason and must be reestablished, the Industry Member should populate the ltidEffectiveDate with the date on which the LTID or ULTID became re-associated to the FDID within the CAT Reporter’s system- not the original LTID Effective Date.
- FAQQ9. What is an Unidentified Large Trader ID (ULTID) and are all Industry Members required to report ULTIDs to CAT CAIS?
As described in the Customer and Account (LTID) Technical Specifications, in the scenario a CAT Reporter that is a clearing firm or self-clearing firm determines a person (which includes both natural persons and legal entities under Section 13(h)(8)(E) of the Exchange Act) would qualify as a large trader, but the firm has not yet been provided with an LTID by the person, the clearing firm or self-clearing firm is required to assign an ULTID to the person until such time as the person provides their LTID.