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.
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
Cat Implementation Timeline
Upcoming Key Dates:
- January 4, 2021 – 2b (options) Firm-to-Firm Linkage, TRF/Exchange Linkage
- January 25, 2021 – Test Environment opens for Equities Phase 2c file submission and data integrity
- 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.
Listen to our latest CAT podcast:
Recent and Relevant Blogs:
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
The Consolidated Audit Trail (CAT) is Live 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? 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