What time does S3 need the input file(s) for CAT processing?
S3 expects the input file to be delivered by midnight ET.
When will S3 start processing the CAT input file(s)?
S3 will start processing the input file upon receipt.
How is the client notified of submission issues (named and unnamed)?
FINRA requires each firm to review the submission log (on the FINRA CAT portal) on a daily basis. Details on named and unnamed errors will be provided on the FINRA CAT portal.
Is S3 notified of CAT Submission issues?
FINRA notifies S3 of any unnamed errors. However, FINRA has advised S3 that FINRA expects broker-dealers to initiate error investigation, and as such S3 now requires clients to notify S3 of errors before S3 can begin investigation of these errors. Upon notification, S3 will investigate the unnamed errors to determine if the issue is caused by the input file, the counterparty, or S3’s handling of the data. FINRA does not notify S3 regarding named errors.
How does the client notify S3 of any named errors?
The client will need to send an email to help@s3.com / cat-support@s3.com with the details of the named error(s). Note the details are especially important for named errors, which S3 does not receive from FINRA.
What happens if there are any issues with data in the input file?
S3 will process the entire input file and records that pass the data quality checks will be submitted to FINRA. The problem records will be logged internally and the S3 team will be alerted. S3 will contact the client regarding the problem the following business day. The details of the problem records will also be available in the S3 portal. S3 will make reasonable effort to assist with researching the cause of the problem (which could span outside the T+3 window).
If the client needs to fix a problem with the input file, what is the process to send the new file to S3?
The client can send the new file (with the same filename) to the same SFTP server the original file was sent. S3 will run in the new file upon receipt.
What is the process to resolve a problem if the issue is on the S3 side?
S3 will make commercially reasonable attempts to resolve the problem within 3 business days.
What is the process to resolve a problem if S3 represents both my firm and the counterparty?
S3 will coordinate between the client and the counterparty to fix the issue. S3 will make commercially reasonable attempts to resolve the problem within 3 business days.
When will the client / S3 know if the problem has been resolved?
FINRA will run the record acceptance / linkage process beginning at 8:00am ET the following business day. Any new or unresolved errors will be reported to S3 at this time. If there are no new or unresolved errors reported during the re-run of the record acceptance / linkage process, the problem should be considered resolved.
What is the process to resolve a problem if the issue (linkage or otherwise) is on the counterparty side?
S3 will report the problem to the counterparty, providing details of the issue. The client will also been copied on the notification to the counterparty. At this point, it is the responsibility of the counterparty to resolve the issue. The client will need to contact the counterparty for any further updates on the issue.
What is the process to add new counterparties to the input file?
S3 requires at least 72 hours notice when adding new counterparties to the input file. S3 cannot guarantee the successful processing of any new counterparty if notification is inside the 72 hour window. If the client is sending a daily counterparty mapping file, then 72 hours notice is not required.
What is the process if the client or third-party provider needs to make updates to the input file?
S3 will need at least 10 days advance notice regarding any changes to the input file formatting or structure. Additional details about the update(s) may be requested, depending on the nature of the change. S3 cannot guarantee the successful processing of the updated input file if notification is inside the 10 day window.