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 to over 30%. There were also significant delays in the timely delivery of feedback data from FINRA CAT, further reducing the time industry members have to make any required repairs to rejected events in the T+3 window.
It is important to note that several systematic sources of rejected events contributed to some rejections. Most have been resolved in the past few weeks. A significant item that impacted several of our clients was related to the CAT reporting of Market Making Quotes, both PEG and STUB, to a national exchange. In many cases these systematic errors created consequential “noise,” making it more difficult to focus on legitimate errors. Now that these issues are resolved, our clients can focus on rejections related to actual daily use cases.
As of November 17, 2020, the latest industry statistics continue to trend with initial rejection rates hovering around 3%, or just under 90 billion equity records. These statistics include Interfirm data as well as Exchange and TRF linkages. Adjusted rates on a T+3 basis support that industry members are actively working to resolve the initial rejections across the board.
Oyster’s CAT team can assess how your firm is currently positioned for CAT reporting as well as help manage your requirements for future implementation phases. Oyster Consulting has experience working with several large CAT reporters and has developed a practical analysis tool. The Oyster CAT Application monitors your firm’s CAT reporting by ingesting CAT reports from any source and combining that data with all feedback files from FINRA CAT. The application also assists with error correction and repair, enhancing your ability to supervise your firm’s CAT reporting. The CAT Application software is designed to conform to the recommendation for CAT Supervisory systems and procedures found in FINRA’s Notice to Members 20-31.