CAIS Reporting and the FDID Refresh Report

Understanding the CAIS FDID Refresh Requirement

On April 3, 2025, FINRA CAIS will publish the first FDID Refresh Report for compliance with the Periodic Customer & Account Information Refresh requirement.

All FDIDs listed on the April 2025 Refresh Report must be refreshed no later than midnight Eastern Time on May 31, 2025.

FINRA’s Monthly FDID Refresh Report Process

Industry Members must refresh all active FDIDs at least once every 12 calendar months. Active FDID Records are those that have no “fdidEndDate” or the “fdidEndDate” is set to a date greater than the current calendar date. These FDIDs are required to be resubmitted and accepted into CAIS no less often than every 12 months.

FINRA CAIS will continue to generate The FDID Refresh Report monthly and will publish it in the FINRA CAIS Portal on the third CAT Trading Day of each month. The report contains a list of active FDIDs that were last accepted at least 11 calendar months prior to the month of the report. Any FDIDs not refreshed within the 12-month period will be marked as overdue and will negatively impact the Firm’s CAIS Report Card.

If Industry Members submit an FDID Record before the 12-month deadline which is subsequently accepted into CAIS, the 12-month cycle is reset from the date of that submission.

The periodic refresh cycle ensures that FDID records and associated customer data remain accurate and up-to-date, meeting regulatory requirements for CAIS reporting.

Preparing for the Periodic CAIS Refresh

Industry Members must make the necessary updates to their internal policies and procedures.

Reflect the 12-Month Refresh Requirement

Policies and procedures should reflect the 12-Month Refresh Requirement and clearly state that all active FDIDs must be refreshed at least once every 12 calendar months.

Define Roles and Responsibilities

Specify which teams, internal personnel or reporting agent associates are responsible for outlining procedures for:

• Outlining procedures for monitoring and identifying FDIDs coming due periodic refresh in the CAIS system.
• Identifying the party responsible for submitting the periodic refresh report.
• Coordinating with any reporting agents reporting on behalf of the firm.
• Implementing controls to ensure compliance with the periodic refresh requirements.

Enhance Training and Compliance Awareness

• Provide internal training needed to comply with the FDID periodic refresh for regulatory compliance and audit trail maintenance.
• Communicate to internal compliance teams to ensure awareness that overdue FDIDs will be tracked in CAIS Report Cards.

Software Solutions for CAT and CAIS Reporting

Founded on the success of our industry-leading GRC software, the Oyster Solutions CAT reporting module consolidates all CAT reporting events, error analysis, and validation data into one central program. This powerful application helps identify errors, connections, and missing information in vendor data and CAT-reported data, making the reporting process easier and more efficient for you.

The  Oyster Solutions CAIS Module lets you see CAIS reports and source data on one platform. You can use it with or without the CAT Application. Companies can achieve Full CAIS reporting with the help of a web-based tool. This tool helps them identify and correct errors in their data.

CAT Compliance Support: Ensuring CAIS Reporting Accuracy

Oyster Consulting provides comprehensive consulting for CAT and CAIS reporting, from performing providing a comprehensive assessment of your CAT and CAIS policies, procedures and controls to performing simple due diligence on CAT Reporting Agents. Oyster Consulting’s regulatory compliance experts can also assist you with best practices for CAT and CAIS regulatory requirements, interpretations, and benchmarking.