On June 17, 2021 FINRA filed a proposed rule change to retire OATS as of September 1, 2021, deleting OATS Rules from the FINRA rule book. The last OATS business day will be August 31, 2021.
- All order events submitted to OATS occurring after this date will be rejected.
- Late or corrective reporting will be accepted by OATS until September 16, 2021.
- Further guidance is expected in an up-coming Regulatory Notice.
What Firms Should be Doing
Industry members reporting to OATS are encouraged to review their submission protocols as well as their internal firewall rules. Firms should also notify their Super Account Administrator (SAA) so that entitlements can be reviewed and adjusted as needed. Firms should also communicate with any service provider supporting their OATS reporting.
Firms should review their overall trade reporting structure since they will be relieved of the simultaneous dual reporting to OATS and CAT. Staffing and subject matter expertise may be adjusted, allowing firms to focus more time and resources on the accuracy of their CAT reporting. Third party vendors have come a long way in being able to assist firms with automated solutions for CAT analysis and rejection/repair support.
This change may be an opportunity for increased regulatory scrutiny on CAT reporting. We continue to see formal and informal inquiries related to overall CAT reporting rejection rates as well as more specific sweeps of reporting accuracy. Firms need to be prepared to demonstrate their CAT Reporting supervisory programs if the firm reports on its own behalf or if it has outsourced reporting to a CAT Reporting Agent (CRA).
Oyster Consulting’s team of experienced professionals will ensure that your regulatory reporting is efficient and compliant. In addition to trade reporting compliance, we deliver our industry expertise developed through practical consulting during the implementation of the Consolidated Audit Trail (CAT). Our consultants use their deep regulatory experience coupled with our Oyster Solutions CAT Application to provide firms with what they need to meet and exceed their CAT reporting obligations. For more information about how Oyster can help your firm with Trade or CAT reporting, click here or call (804) 965-5400.