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 proposed a rule later that year – and approved the final version, Rule 613, in 2012 – that would require the Self-Regulatory Organizations (SROs), comprised of securities exchanges and the Financial Industry Regulatory Authority (FINRA), to develop and implement the CAT.

The design of this system will allow regulators to link all reportable events from origination through its entire life cycle, including cancellations, modifications, executions or cancels, across all U.S. markets in the National Market System (NMS). When developed, the CAT will be a single comprehensive database that links all orders with the account holder, or person who has trading discretion over the account, thereby enabling regulators to conduct cross-market analysis without obtaining and merging together large volumes of disparate data from different entities.

Thesys Technologies LLC was selected by the SROs in January 2017 to build the CAT. As development continues to support this major initiative, SIFMA is engaged with Thesys on allocations, equity and listed options orders and executions, and firm-designated IDs.

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