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Are verbal and manual quotes subject to the reporting requirements of Phases 2a, 2b, 2c or 2d?

Are verbal and manual quotes subject to the reporting requirements of Phases 2a, 2b, 2c or 2d?

No. In accordance with the SEC’s July 28, 2023 order granting a temporary conditional exemption relating to the reporting of certain on and off (including in the over-the-counter market) floor activities, Industry Member CAT Reporters are not required to report the following during Phases 2a, 2b, 2c or 2d: (1) floor broker verbal announcements of firm orders on an exchange that are otherwise reported as systematized orders; (2) market maker verbal announcements of firm quotes on an exchange trading floor; (3) telephone discussions between an Industry Member and a client that may involve firm bid and offer communications; and (4) unstructured electronic and verbal communications that are not currently captured by Industry Member order management or execution systems. 

However, this verbal and manual activity will be required to be reported in future phases of CAT, as the SEC’s order expires on July 31, 2026. See CAT FAQ C-7 for additional information on orders considered “manual” or “electronic” for purposes of reporting to the CAT.