If an Industry Member receives an order for a security that is dually listed with specific instructions that the order Accounting Errors is to be executed on the foreign market, then the Industry Member should populate the tradingSession field with the code “FOR” (to be executed only on a Foreign Market). It is important to note that the FOR value may only be used in instances where the order can only be executed on the foreign market. If it is possible that the order could be executed in the US, then the tradingSession field should be populated with the Trading Session value that reflects the sessions during which the order is eligible to trade in the US.
Exam Findings and Effective Practices
Please contact each Option Exchange directly for guidance on CAT reporting obligations for Option Market Maker quoting activity on exchange-specific protocols. A representative order may have order level linkage without fulfillment level linkage (e.g., unexecuted order), and may have fulfillment level linkage without order level linkage (e.g., a customer order filled from a pre-existing principal order such as a Manning execution, or in the case of a disconnected OMS/EMS). A representative order may also have both order and fulfillment level linkage with different values populated in the representativeInd and fulfillmentLinkType fields (e.g., the firm order originated to represent the order was not the order that was ultimately used to fill the customer order). Refer to Appendix C of the IM Technical Specifications for additional information.
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- The eventTimestamp on an Allocation event should reflect the date and time when the shares or contracts allocated are booked into the customer or client’s account.
- In March, the SROs filed an amendment to the CAT NMS Plan that included a prohibition on the collection of PII and provided for the destruction of PII stored in the CAT.
- Any legal analysis, legislative updates, or other content and links should not be construed as legal or professional advice or a substitute for such advice.
- The receiving US broker-dealer is required to report the receipt of an order from a non-US broker-dealer in the same way as it would report the receipt of an order from a Customer.
- The Industry Members providing responses to the solicitation of interest do not have any reporting requirements in Phase 2a/2b.
- When reporting an allocation event or amended allocation event, the clearing firm may report the accountHolderType from the perspective of the correspondent firm rather than “flipping” the accountHolderType to the perspective of the clearing firm.
Regulatory Notice (FINRA Reminds Firms of Their Supervisory Responsibilities Relating to CAT) describes practices and recommended steps firms should consider when developing and implementing their CAT Rules compliance program. Regulatory Notice (FINRA Reminds Firms of Their Supervisory Responsibilities Relating to CAT) describes practices and recommended steps member firms should unearned revenue consider when developing and implementing their CAT Rules compliance program. Section 5 of this Guide provides an overview of the Industry Members Technical Specifications and the CAT Industry Member Reporting Scenarios documents. Firms should refer to these documents, as well as the FAQs, published on CATNMSplan.com, to gain an understanding of the approved and up-to-date reporting requirements for CAT. CAT will include a substantial number of additional requirements, such as options data, allocations, and customer data that are not considered within the current OATS requirements. Errors must be corrected within three trading days (T+3) of the Reportable Event.
- The ‘ALG’ handlingInstructions value must not be used on routes that are sent by an algo.
- This plan governs the establishment, operation and administration of a market-wide limit up-limit down mechanism that is intended to address extraordinary market volatility in NMS stocks, as defined in Rule 600 of Regulation NMS under the Exchange Act.
- (6) The term error rate shall mean the percentage of reportable events collected by the central repository in which the data reported does not fully and accurately reflect the order event that occurred in the market.
- A representative order may also have both order and fulfillment level linkage with different values populated in the representativeInd and fulfillmentLinkType fields (e.g., the firm order originated to represent the order was not the order that was ultimately used to fill the customer order).
- Appendix C of the Industry Member Technical Specifications provides details of the required linkages in these workflows.
SIFMA Fixed Income Market Close Recommendations in the U.S., the U.K., and Japan for the U.S. Martin Luther King Day
Outsourcing a function to a vendor or other third party does not relieve the Industry Member of its ultimate responsibility for compliance with the CAT Compliance Rules or other applicable securities laws, rules or regulations (e.g., SEC Rule 17a-4). An example of the use of an Entity ID as an FDID would be when Industry Member 1 has an employee that is a registered representative that has discretion over several client accounts held at Industry Member 1. The registered representative places an order that he will later allocate to individual client accounts. At the time the order is placed, the trading system only knows it is a representative of Industry Member 1 and it does not have a specific trading account that could be used for FDID reporting.
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There are several considerations such as using a centralized or federated model, buying or building in-house solutions, utilizing the services of a third-party vendor or any combination of these factors. Data and technical architecture considerations are discussed in section 6 of this Guide. Originating with Rule 613, CAT is a comprehensive Consolidated Audit Trail that will allow regulators to efficiently and accurately track all activity throughout the U.S. markets in National Market System (NMS) securities.
