Consolidated Audit Trail (CAT)

SIFMA has long supported the efforts of the Securities and Exchange Commission (SEC) to create a comprehensive Consolidated Audit Trail that would enable regulators to efficiently and accurately track all activity throughout the U.S. for listed-equities and options. SIFMA advocates for a secure system that expedites the retirement of duplicative systems, while promoting an inclusive governance structure and equitable funding model.

In response to the “flash crash” in 2010, the SEC directed self-regulatory organizations (SROs), comprising securities exchanges and the Financial Industry Regulatory Authority (FINRA), to develop and implement a Consolidated Audit Trail (CAT) that will enable regulators to efficiently and accurately track all activity throughout the U.S. for equities and listed options.

The design of this system will allow regulators to link every order through its entire life cycle, including cancellations, modifications and executions. When developed, the CAT will be a single comprehensive database that will link all orders with the account holder or person who has trading discretion over the account, thereby enabling regulators to conduct cross-market analysis while obtaining and merging together large volumes of disparate data from different entities.

SIFMA advocates for a secure CAT system that expedites the retirement of duplicative systems, while promoting an inclusive governance structure and equitable funding model. As development continues to support this major initiative, SIFMA is engaged with the SEC, the SROs and FINRA (the CAT Plan Processor) on data security and implementation issues.

CAT Reporting Timeline – Key Dates

  • March 18-June 27, 2019: Consolidated Audit Trail Registration
  • September 30, 2019: Connectivity testing begins
  • December 16, 2019: Industry testing begins
  • June 22, 2020: Initial equities reporting for large broker-dealers and small broker-dealers that currently report to FINRA’s Order Audit Trail System (OATS)
  • July 20, 2020: Initial options reporting for large broker-dealers
  • Dec. 13, 2021:  Full equities and options reporting for large and small broker-dealers
  • July 11, 2022: Full customer and account reporting for large and small broker-dealers

See SEC Exemptive Order for Phased Reporting Timelines with Conditional Exemption for Impacts of COVID-19 and the CATNMS Timeline

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