New CAT FAQs and Reporting Scenarios
On October 8, 2019, Consolidated Audit Trail, LLC and FINRA CAT, LLC added three new Frequently Asked Questions (FAQ’s) to the master FAQ list on the catnmsplan website.
FAQ D26 details reporting requirements related to Order Receipt reporting obligations. Specifically, the new FAQ provides guidance and clarity on contingent order handling instruction flags.
The second and third new FAQ’s, F5 and F6, cover questions related to Representative Order reporting. As with any new regulatory initiative, not all firms are created equal, and this type of clarity is needed as Industry Members create the infrastructure needed for reporting. Firms should make sure they have an internal individual or group responsible for tracking these alerts and changes as they are released. If your firm is using a vendor to complete its CAT reporting, don’t be afraid to pick up the phone and understand the vendor’s interpretation of the new guidance and how this may impact your firm.
Oyster Consulting can help you with your assessment of how your firm is positioned for CAT readiness and help you manage your requirements assessment and implementation phases. We can also assist you in determining what and how your technology providers will report for you, in testing data scenarios and data linkage, and with creating an error repair process.
Contact us to learn more about the CAT implementation process, and how Oyster can help.
About the author:
Ralph Magee is a Senior Consultant with over 20 years of experience in the financial services industry. Through a variety of roles with Wachovia Securities, LLC and The Financial Group of Virginia, Ralph gained his expertise in clearing conversions, trading, compliance, and retail brokerage, including his extensive understanding of trading and regulatory reporting of equity and fixed income securities. A member of the Oyster Consulting team since 2010, Ralph has led multifaceted teams in large-scale client remediation and clearing platform conversion-related projects. Ralph has also completed the registration of RIAs, designed and implemented compliance programs, personal trading compliance review systems and national trade suitability review programs. The ability to keep projects on track, within scope and on budget, is one of Ralph’s greatest skills.