
By Ralph Magee
Subscribe to our original industry insightsDespite the current global health and market difficulties, the Consolidated Audit Trail (CAT) is still a hot topic in the industry. The SEC has provided Exemptive Relief through a No Action Letter until May 20, 2020, though the participants have requested additional relief. This has impacted a few of our customers who have reacted to the call of the industry and have been aggressively preparing for the original timeline for CAT implementation.
In recent weeks, our Business Development and CAT teams have started to receive phone calls and correspondence from firms who may have been following industry news regarding CAT but were potentially expecting additional delays. Others are feeling pressure that they are not as far along in this initiative as their peers. Understandably, some may have based their stance on the multi-year postponements the industry has seen since SEC Rule 613 was approved in 2012. We have also noted that firms may have relied solely on the clearing firms or OMS provider to produce and validate their CAT reporting. In some cases, these firms have come to the realization that, in addition to their designated CAT Reporting Agents (CRAs) having to certify with FINRA, each firm’s IMID must also be certified for the production environment of CAT.
As practitioners, we fully expected the two previously mentioned categories, and we anticipate each to continue into 2022 as the phase implementations of CAT are initiated (Phases 2b, 2c, 2d and 2e). We are also preparing for a few additional waves detailed below:
Oyster can also assist in testing data scenarios and data linkage, as well as creating an error repair process. Firms can also leverage the Oyster CAT application to gather and analyze reported data and errors.
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