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COMMENT LETTERS - REGULATORY COMPLIANCE INFORMATION

CAT Customer and Account Information System ("CAIS") (3/24/21)

CAT Customer and Account Information System (CAIS)

Industry Member Onboarding Guide

As Recreated by Small Firms for Small Firms (3/24/21)

Step 1 of 5 CAIS REGISTRATION

1. Register with CAIS. All Industry members and CAT Reporting Agents that will submit trades related to an account with a LTID or submit Customer and Account information must register for CAIS. Go to https://www.catnmsplan.com/cais-registration , click on Register for CAT CAIS (link), enter your firm’s information and Submit.

Small Firm Tips:

 “LTID” stands for Large Trader ID. One example of what a large trader is would be is if your firm has an affiliated investment adviser that meets the definition of a large trader per the Exchange Act Rule 13h-1. That advisory company will be a Large Trader of the broker-dealer and must report their LTID to you, the broker-dealer. All firms reporting to CAT will also need to comply with the Customer and Account information requirements of CAIS. Refer to https://catnmsplan.com/timeline .

 “Primary CAT CAIS/LTID Report Source”. The vast majority of small firms will not submit their transactions into CAT/CAIS directly. Rather, small firms will (by and large) have an arrangement wither with their clearing firm or third-party vendor serve as their CAT/CAIS Submitter. Therefore, most small firms should answer “CAT Reporting Agent” here.

 “Secondary CAT CAIS/LTID Report Source”. For most of us, this is where we will enter Self-Reporting (meaning, if something goes wrong with our clearing agent, the small firm is responsible for manually accessing the CAT/CAIS system and fixing trades), unless you have two outside vendors, one as your primary source and one as your secondary – then you would enter CAT Reporting Agent here, too.

 “Submission Connectivity”. For small firms that will utilize their clearing firms as their Reporting Agent (or a third-party vendor), the answer here will be Reporting Agent.

 “Preferred Connectivity Type if Self-Reporting”. For most small firms, the answer here will be CAIS Reporter Portal.

 Before you click to submit the CAIS Registration Form print or save the form as a PDF so you can refer back to the information you provided FINRA CAT/CAIS.

2. You will receive an email from FINRA CAT that your CAIS registration to the TEST ENVIRONMENT SITE has been processed and approved. Once you receive this, log into the FINRA Gateway, go to the FIRM GATEWAY, click on User Administration, scroll all the way down to the bottom of the page and hit Search. This will display all users on your Firm Gateway and what each person is permissioned to do/see.

3. Now you need access. Your firm’s SAA (Super Account Administrator) is the person authorized to grant all individuals access to CAT and CAIS Test and Production Sites (User rights and Admin rights). Click on your User ID, scroll all the way down to the bottom of your profile to “CAIS Reporter” and confirm you have both User and Administrator access for the “Reporter User”- you will need both to proceed. If both User & Admin are not checked, you will need to contact your SAA to ask them to entitle you as both a CAT Industry Member Reporting Agent User and CAIS Reporter User.

Small Firm Tip: Even the SAA needs to entitle him/herself to have access to the CAT or CAIS Reporter Portal.

Step 2 of 5 ESTABLISH CAIS REPORTING RELATIONSHIP IN TEST ENVIRONMENT

4. This is the point at which you will open the Industry Member CAIS Onboarding Guide (you will need the Guide for the links imbedded in the document).

5. If your firm acts as your own Reporting Agent (entity that reports all of your equities and options transactions into CAT) or if you have set up a machine-to-machine (SFTP) connection to securely transmit data to CAIS, please go to page 11, item 4 and follow the instructions. (Most small firms are not their own Reporting Agent and will skip this section and go straight to the next bullet point below: Item 5.)

6. After Registration, the next step is to “Establish CAIS Reporting Relationships in the Test Environment”. To accomplish this, please go to page 12, Item 5 of the Onboarding Guide. Click on the “CAT Reporter Portal User Guide” link in the Guide. Copied here: Registration & Onboarding | CATNMSPLAN

a. Next, click on the “CAT CAIS Registration & Onboarding” link. Scroll down to the “Resources” section and click on the “CAT/CAIS Reporter Portal User Guide” link. (Copied here: 11.04.20-CAIS-Reporter-User-Guide-1.1.0.pdf (catnmsplan.com)

b. You are now in the “Industry Member CAT CAIS Reporter Portal User Guide”. Go to Page 7, Item 3 (Access Information) and click on the top, right link:

“CT/Industry Test URL”: https://srg.ct.catnms.com

7. You are now on the FINRA CAT Reporter Portal login page. Enter your FINRA Gateway credentials (not your FINRA CAT credentials) and affirm your Duo push. You will now be in the “CAT Reporter Portal” test environment. To confirm this, you should see “THIS IS A TEST ENVIRONMENT” (in red) at the top of the webpage.

Small Firm Tips:

 Should you happen to be reading the Onboarding Guide, it says you are going to the CAIS Reporter Portal, but the screen you will be looking at instead reads “CAT Reporter Portal”. Don’t let that confuse you, we’ve brought you to the right place through our instructions.

 At the top of the page, you will see a drop-down box for “Perspective”, change this to “All”. Get in the habit of doing that when you first login to ensure you can view all the information you have access to.

8. On the left-hand, blue vertical icon menu click on the Reporting Relationships icon. Now select CAIS Reporting Relationships on the horizontal tab to the right of Transaction Reporting Relationships (which is the tab that will list your CAT Reporting Relationships).

Small Firm Tip:

 The relationships will likely be the same on both tabs: Transaction Reporting and CAIS Reporting.

a. Click on the Add New button/option (blue, over to the right of Reporter View).

b. Using the dropdown menu select your Submitter’s information, which will either be your clearing firm or third-party vendor engaged through your clearing firm.

Small Firm Tip:

 Do not guess. Confirm with your clearing firm or third-party vendor the CAT and CAIS reporting services they will be providing and the correct relationship submitter number to choose from the drop-down menu.

c. Effective Date: Enter the date you are doing this data entry.

d. In the Expiration Date field enter “12/31/2099”. Yes, that is 2099, far into the future. Then click SAVE.

9. Now verify your information in the Reporter View: (It may be confusing that is says “CAT Submitter” under the “CAIS Reporting Relationships” tab, but you are in the right place)

CAT Rep CRD ID: Your firm’s CRD number

CAT Submitter CRD ID: (Submitter’s CRD ID)

Effective Date: (date of data entry)

Expiration Date: 12/31/2099

Created By: (user ID)

Created On: (current Date/Time)

Updated By: (user ID)

Updated On: (date/time)

Small Firm Tips:

 For future reference, if you should ever need to edit any of this information, you will navigate yourself to the production website and then scroll all the way to the right in order to find the Edit icon option.

 Select Export and save this information into your CAT/CAIS folder on your network drive or computer (hint, hint: create that folder if you haven’t already), as both a confirmation and a reminder of how you set up your firm’s reporting relationship for CAIS.

10. You have now completed the 1) CAIS Registration and 2) CAIS Reporting Relationship requirements of the CAIS Test environment. Please notify your submitter that you have assigned them as your CAIS Reporting Agent, so they know your firm is ready for the next phase of CAIS implementation: transaction data submission and testing.

Step 3 of 5 CONDUCT TESTING FOR PRODUCTION READINESS

11. Your Reporting Agent (Submitter) will need to submit transaction-related data to FINRA CAT/CAIS. After they send one or more files to FINRA CAT, you should receive notification from your Reporting Agent that data was submitted.

12. When data has been submitted, log back into: https://srg.ct.catnms.com and enter your FINRA Gateway credentials (not your FINRA CAT credentials) and affirm your Duo push. You will now be in the “CAT Reporter Portal” test environment indicated by THIS IS A TEST ENVIRONMENT.

13. On the left-hand side of the home page, on the blue icon menu, please look all the way at the bottom of the menu and click on the “CAIS” icon.

Small Firm Tips:

 Remember, clicking on this icon, from this specific website, is the only way to get into the CAIS Reporter Portal.

 Once you have clicked the CAIS icon, it should say “CAIS Reporter Portal” in the upper left-hand corner of your screen.

 You will be able to switch back and forth from the CAT and CAIS site by clicking on the icon in that section of the website (on the CAT Reporter Portal page it is the “CAIS” icon and on the CAIS Reporter Portal the lower left-hand screen toggle icon is titled “Transaction Data”).

14. Select the Submissions icon on the left-hand, blue vertical icon menu.

15. Select the fourth tab, Completed Submissions on the horizontal tab line to view the test data.

Now, review the data being submitted on your behalf.

a) CAIS Reporter Portal/Home, you will see the “Maximum Allowable Error Rate” of 5% (that is the error rate percentage number your Reporting Agent and your Firm need to be under)

b) Select Reports from the left-hand vertical icon menu

c) Select the Submission Report tab

d) In the drop-down menu for “View Data For:” change to ALL – you will see data and the error rates, etc.

e) Call the CAT Help Desk (888-696-3348) to review your data submission and error rate with someone on the Help Desk. They will compare your registration form with what they are seeing, as far as the data that was submitted on your behalf. If everything looks good, the Help Desk will forward your account to a FINRA Analyst for the final review and approval (the approval will be sent via email).

16. To get back to the CAT Reporter Portal Test Environment, click the Transaction Data icon on the left-hand, blue vertical icon menu.

Step 4 of 5 CAT CAIS PRODUCTION APPROVAL NOTIFICATION

17. Your firm’s SAA will receive an email from FINRA CAT Helpdesk and the Subject line will read: CAT CAIS Production Approval CRM: xxxxxxxxxxxxx.

Small Firm Tips:

 This email is your official notification from FINRA CAT-CAIS that your firm and Reporting Agent have met the criteria to achieve the CAT-CAIS LTID production readiness certification.

 Let your submitter know your firm is approved for production.

18. Access to the (Live) CAIS Reporter Portal will not yet be active. In approximately three business days, your firm's SAA will receive an email notification from CATIMAccess@finracat.com to indicate access to the CAIS Reporter Portal production environment has been granted and is available.

Small Firm Tips:

 Here again, entitlement to the (Live) CAIS Reporter Production environment will not happen automatically.

 Your firm's SAA will need to access the FINRA Firm Gateway User Administration to, first, grant him/herself access to the (Live) CAIS Reporter Production environment.

 Next, if your firm will have more than one person permissioned on CAIS, your firm’s SAA will need to entitle other CAIS Reporter Portal users with the FINRA - Login ability to access the (Live) CAIS Reporter Production environment.

 Your SAA will see a 3rd access option under CAIS Reporter labeled “Reporter LTID Production User”.

19. Once entitled, users will be able to access the CAIS Reporter Portal (Live) Production Environment through the CAT Reporter Portal at https://srg.catnms.com .

Small Firm Tip:

 The link to CAIS will be found in the lower-left corner of the blue navigation bar on the CAT Reporter Portal, like it was in the test environment. Users will be able to switch back and forth between portals by clicking the icon in this location.

20. When you log into the CAT Reporter Portal production site – you should NOT see THIS IS A TEST ENVIRONMENT. If you do, check your URL because you logged into the Test site by mistake.

Test URL: https://srg.ct.catnms.com

Production URL: https://srg.catnms.com

Step 5 of 5 ESTABLISH CAIS REPORTING RELATIONSHIP FOR PRODUCTION

21. The next step is to establish your firm’s CAIS Reporting Relationships for Production (in the Live environment). Refer to Step 2 of 5 herein and repeat here in the live production environment.

Small Firm Tip:

 Follow the same process that you completed to set up your firm’s Reporting Relationship in the Test Environment, but now you are doing it in the Live environment.

We really hope these plain-English procedures and Small Firm Tips have helped facilitate a (relatively) smooth registration, test environment setup, testing, certification, and Live environment setup process.

- Jennifer Szaro and Paige Pierce

Paige Pierce