CAT – Phase 2d and Ongoing Challenges

The industry has successfully implemented phase 2a,2b and 2c of CAT reporting and testing has begun for phase 2d which has a compliance go-live date of December 13th, 2021.  For the most part, transactional reporting has gone well. Phase 2d will bring more complex products requiring multi-leg reporting scenarios.  However, there are still some aspects… READ MORE

OATS Anticipated Decommission Date Announced

On June 17, 2021 FINRA filed a proposed rule change to retire OATS as of September 1, 2021, deleting OATS Rules from the FINRA rule book.  The last OATS business day will be August 31, 2021. All order events submitted to OATS occurring after this date will be rejected. Late or corrective reporting will be… READ MORE

Update: Decommissioning OATS Reporting

FINRA CAT held their monthly implementation update call on Thursday, March 18th, 2021.  In addition to providing normal status updates on CAT reporting, FINRA REG joined the call to provide an important update on the decommissioning of OATS reporting.  As stated in our September 2020 blog on this topic, CAT reporters are extremely eager to… READ MORE

Consolidated Audit Trail: Moving on to Phase 2c

Now, more than ever before, firms need to prepare for the increase in CAT Reporting complexity and make sure they are well-positioned to surveil CAT reporting. On January 4, 2021, the last implementation of Option linkage compliance came into effect, and the industry completed the 2a and 2b phased implementation of CAT (Consolidated Audit Trail)…. READ MORE

CAT Participants Seek Exemptive Relief

On December 4, 2020 CAT Plan Participants submitted two exemptive relief requests to the Securities and Exchange Commission (SEC): A request for exemptive relief from certain provisions of the CAT NMS Plan related to initial data validation, lifecycle linkages and communication of errors by T+1 at 12:00pm ET In this request the CAT Plan Participants… READ MORE

Repairing CAT Accepted Late Trades

In FINRA’s Notice to Members 20-31, members are asked to consider incorporating into their Consolidated Audit Trail (CAT) supervisory system “Daily review of the CAT Reporter Portal to: identify late trades.” While the FINRA CAT portal provides a count of events which were “Accepted Late,” it does not identify what constitutes an Accepted Late trade…. READ MORE

Early CAT Reporting Struggles Lead to Improved Error Rates

Compliance for the Firm-to-Firm/Exchange/TRF linkage implementation phase of Consolidated Audit Trail (CAT) reporting came into effect October 26, 2020.  In the weeks leading up to this there were significant concerns around how the industry would be able to bring error rates down to an acceptable level after the initial rejections rate, in some cases, soared… READ MORE