CAT Interim Reporting Obligation Delayed

On November 22, 2022 FINRA CAT announced updates to the interim reporting obligation schedule outlined in CAT Alert 2022-01. This delays the Interim Reporting Obligation 4 from December 5,2022 to March 10, 2023 as well as the Full Compliance date from December 12, 2022 to March 17, 2023.

Interim Obligation 1 – No change
Interim Obligation 2 – No change
Interim Obligation 3 – No change
Interim Obligation 4 – Moved from December 5, 2022 to March 10, 2023
Full Compliance Go-Live – Moved from December 12, 2022 to March 17, 2023

Another substantial part of this announcement is a delay to the FDID validation between CAT Transaction data and CAIS, as well as fully disabling the nightly data inconsistency feedback files. Both validations are expected to be enabled again sometime in January of 2023.

The plan provider has recently experienced significant pushback from the participants and Industry Members related to the above validations, feedback files and information provided on the FINRA CAT portal.

Oyster Consulting’s proprietary Consolidated Audit Trail reporting software includes a CAIS module that can be utilized by firms who do not use the CAT Application for monitoring and evidencing their CAT reporting. Our software consolidates CAT reporting events, error analysis and validation data into a central program. The CAT Application then will identify errors, linkage and gaps between vendor data and CAT reported data.

Our consultants use their deep regulatory experience in trade reporting to help firms achieve their CAT reporting obligations and get the most out of their CAT reporting investment. Leverage our expertise and software to ensure your reporting meets regulatory requirements.

About The Author

Ralph Magee Jr. is a Senior Consultant with over 20 years of experience in the financial services industry. Ralph has led multifaceted teams in large-scale client remediation and clearing platform conversion-related projects. Ralph also uses his expertise in trade reporting providing large broker dealers project management and subject matter expertise related to the Consolidated Audit Trail (CAT).

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