Consolidated Audit Trail (CAT) Implementation

Oyster Consulting delivers clients industry expertise developed through practical consulting during the on-going implementation of the Consolidated Audit Trail (CAT).  Our consultants use their deep regulatory experience coupled with our Oyster Solutions CAT Application to provide firms what they need to meet and exceed their CAT reporting obligations. 

CAT Process

Without the Oyster Consulting team and the tool that they designed for Consolidated Audit Trail reporting, our firm would not have been as prepared for CAT reporting and ahead of the process as we are. The tool has met all of our needs and the Oyster team is able to act quickly to make modifications if necessary.”  – COO, BB&T Securities, LLC

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Cat Implementation Timeline

CAT Timeline 061720

Upcoming Key Dates:

  • April 26, 2021 – Production Go-Live for Equities 2c reporting
  • April 26, 2021 – LTID account information reporting Go-Live for 2a, 2b and 2c for large industry members
  • April 28, 2021 – Test Environment opens for Options Phase 2d file submission and date integrity
  • December 31, 2021 –  Production Go-Live for Options 2d reporting

Key Areas of Focus for CAT

Firms should be generally aware of their current state assessment for CAT reporting based on the daily feedback received from FINRA CAT. 

We highly recommend that all firms have an assigned CAT subject matter expert that regularly attends the industry checkpoint calls and webinar provided by FINRA CAT. These can be found on their webpage under the Communication tab. 

We are also working with our current clients to establish well defined project plans for the upcoming phased implementation of the industry timeline as well as incorporating any updates to the published technical specifications.

Oyster Can Help

Oyster Consulting can assess how your firm is currently positioned for CAT reporting as well as help manage your requirements for future implementation phases.  Oyster’s team has experience working with several large CAT reporters and have developed a practical analysis tool called the Oyster Solutions CAT Application. This application monitors a firm’s CAT reporting by ingesting CAT reports from any source and combining that data with all feedback files from FINRA CAT.  The Oyster Solutions CAT Application also assists in error correction and repair, enhancing a firm’s ability to supervise CAT reporting.  The application is designed to conform to the recommendation for CAT Supervisory systems and procedures found in FINRA’s Notice to Members 20-31.

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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Additional Resources:

Listen to our latest CAT podcast:

Recent and Relevant Blogs:

Consolidated Audit Trail: Moving on to Phase 2c
Posted on January 26th, 2021 by Ralph Magee
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
Posted on December 2nd, 2020 by Ralph Magee
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

Repairing CAT Accepted Late Trades
Posted on December 2, 2020 by Ralph Magee
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
Posted on November 24, 2020 by Ralph Magee
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
Posted on September 21, 2020 by Ralph Magee
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
Posted on August 12, 2020 by Ralph Magee
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

The Consolidated Audit Trail (CAT) is Live
Posted on June 18, 2020 by Ralph Magee
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. One significant change since the initial adoption of Rule 613 is the speed with which… READ MORE

CAT Goes Live Part 2: What Should My Firm Be Doing? 
Posted on June 25, 2020 by Ralph Magee
As a continuation of last week’s update on CAT activity, we will dive into more detail regarding a few panel comments regarding upcoming milestones found on the compliance timeline.   As we pointed out last week, it has been a remarkable achievement for the industry to have arrived at the compliance implementation for the… READ MORE