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

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

SIFMA and SROs Settle on CAT Reporter Agreement

In a surprising announcement, SIFMA and the Self-Regulatory Organizations (SROs) have reached a settlement on the Consolidated Audit Trail (CAT) Reporter Agreement.  This comes after SIFMA issued a statement last week from Industry Members in support of their accusation of improper SRO action based on Section 19(d) of the Securities Exchange Act of 1934.  Within… READ MORE

New Podcast: SEC Issues Anticipated Exemptive Relief for Consolidated Audit Trail (CAT)

The Consolidated Audit trail (CAT) is moving forward and the SEC has released new exemptive relief dates for parts 2a (Equity reporting) and 2b (Options reporting).  The SEC has also provided exemptive relief for introducing brokers. In this episode, Oyster Consultants Ralph Magee and Jeff Call discuss what firms should be doing around certifications, linkages, testing validation and… READ MORE