Consolidated Audit Trail Implementation

CAT Implementation

In comparison to available competing CAT solutions Oyster was both more cost effective and delivered an equal if not greater amount of functionality.  Their partnership with us in improving the application in a very timely manner has been invaluable. We have also found great value in them coordinating joint calls with their clients so we can all collaborate as a Team.

– DA Davidson & CO.



June 23, 2020 – Eight years after the Security and Exchange Commission (SEC) adopted Rule 613, the Consolidated Audit Trail (CAT) has finally gone live for equity reporting as of Monday, June 22, 2020.  Options reporting will also go live on July 20, 2020. Click here to view dates that dictate what fees or Post Amendment Expenses Participants may be able to collect/recover from Industry Members:

May 14, 2020 – In a surprising announcement, SIFMA and the Self-Regulatory Organizations (SROs) have reached a settlement on the Consolidated Audit Trail (CAT) Reporter Agreement.

This settlement will have the largest impact on firms which had not signed the CAT Reporter Agreement. Those firms will have little more than a month to test and become certified before the compliance Go Live date of Phase 2a of June 22nd, 2020.  Once the revised agreement is published and accepted by reporting firms or CRAs, CAT should see a significant increase in reporting events and firms seeking their production certification.

April 20, 2020 – The SEC announced it has voted to issue two exemptive orders in order to move Consolidated Audit Trail (CAT) implementation forward: (1) establishing a phased CAT reporting timeline for broker-dealers, and (2) permitting introducing brokers that meet certain requirements to follow the small broker-dealer reporting timeline.

Following the April 20, 2020 actions, select milestones for broker-dealer reporting to the CAT are:

  • June 22, 2020: Initial equities reporting for large broker-dealers and small broker-dealers that currently report to FINRA’s Order Audit Trail System (OATS);
  • July 20, 2020: Initial options reporting for large broker-dealers; and
  • Dec. 13, 2021:  Full equities and options reporting for large and small broker-dealers; and
  • July 11, 2022: Full customer and account reporting for large and small broker-dealers.

To learn more about the exemptive relief and what your firm should be doing, listen to our latest CAT podcast episodes:


The Time To Act Is Now

Cat Implementation Timeline

CAT Timeline 061720



This is an excellent opportunity for firms to shift their focus to test the validity of the data being reported, looking beyond syntax checks, and to perform more data comparisons to the source data file used to generate CAT reporting events.

We are recommending that our clients continue to prepare for the implementation of CAT as internal resources allow.

Oyster can help you assess how your firm is positioned for CAT readiness, manage your requirements assessment and implementation phases, interface with your own technology providers, and assist you in determining what and how your technology providers will report for you. We can also assist in testing data scenarios and data linkage, as well as creating an error repair process. Firms can also leverage the Oyster CAT Application to gather and analyze reported data and errors. To learn more about how your firm can leverage Oyster’s CAT Application,  you can schedule a demo and one of our associates will be happy to assist you.

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Related Blogs:

The Consolidated Audit Trail is Live – June 23, 2020

CAT Goes Live Part 2:  What Should My Firm Be Doing? – June 18, 2020

CAT Goes Live – Where Are We Now? – June 11, 2020

SIFMA and SROs Settle on CAT Reporter Agreement – May 14, 2020

Under Looming CAT Deadlines, Firms Try to Land on Their Feet – April 7, 2020

CAT Implementation Delayed Due to COVID 19 – March 19, 2020

CAT Testing – Don’t Lose Sight of Large Trader ID (LTID) and Phase 2c Deadlines – February 4, 2020

Consolidated Audit Trail (CAT) January 2020 Update – January 28, 2020

CAT Connectivity Deadlines – Establish Connectivity Methods and Be Ready for Testing – October 8, 2019

Consolidated Audit Trail (CAT) – Will Your Firm Be Ready To Report? – October 1, 2019