On October 8, 2019, Consolidated Audit Trail, LLC and FINRA CAT, LLC added three new Frequently Asked Questions (FAQ’s) to the master FAQ list on the catnmsplan website.
FAQ D26 details reporting requirements related to Order Receipt reporting obligations. Specifically, the new FAQ provides guidance and clarity on contingent order handling instruction flags.
The second and third new FAQ’s, F5 and F6, cover questions related to Representative Order reporting. As with any new regulatory initiative, not all firms are created equal, and this type of clarity is needed as Industry Members create the infrastructure needed for reporting. Firms should make sure they have an internal individual or group responsible for tracking these alerts and changes as they are released. If your firm is using a vendor to complete its CAT reporting, don’t be afraid to pick up the phone and understand the vendor’s interpretation of the new guidance and how this may impact your firm.
In addition to the updated FAQ’s, the website also uploaded two new documents: a new version of the CAT Terms of Use and the Industry Member Reporting Scenarios v2.4, which reflected details regarding the new FAQ’s.
Oyster Consulting can help you with your assessment of how your firm is positioned for CAT readiness and help you manage your requirements assessment and implementation phases. We can also assist you in determining what and how your technology providers will report for you, in testing data scenarios and data linkage, and with creating an error repair process.
Contact us to learn more about the CAT implementation process, and how Oyster can help.
