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

Decommissioning OATS

Last month FINRA submitted a filing with the SEC outlining their enforcement of CAT regulatory compliance, which included the industry’s goal to retire OATS reporting.  This filing provided additional guidance around FINRA’s plan to ensure the CAT data is complete and accurate before OATS reporting can be fully decommissioned. The Filing states the following data… READ MORE

Regulators Provide CAT Reporting Focus

In the past few weeks, the industry has been given additional guidance on how CAT reporting will be monitored by the regulatory body and the SROs. We were introduced to a new acronym, CMRWG, which is the Cross-Market Regulation Working Group. The CMRWG was recently formed to reduce unnecessary duplication in enforcement efforts. SROs have… READ MORE