September 24, 2021

Volume XI, Number 267

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Consolidated Audit Trail Publishes New Roadmap to Assist Small Firms With Reporting Obligations

On May 7, Consolidated Audit Trail, LLC and FINRA CAT, LLC (CAT) published a new roadmap to assist Small Firms with their reporting obligations for CAT Reportable Securities by the compliance date of December 13. The roadmap has two parts, each with separate steps depending on whether the Small Firm must report data to the CAT Transition System or the CAT Customer and Account Information System (CAIS).

In Part 1 (to report order data to the CAT Transaction System), firms should determine whether the firm handles orders in CAT Reportable Securities, if the firm meets the definition of Small Firm for CAT reporting purposes (firms with total capital of less than $500,000), and if the firm is currently reporting to FINRA’s Order Audit Trail System (OATS). Part 1 then lays out the next steps for registering with the CAT Transaction System, granting entitlement to personnel within the firm, how to submit data to CAT, establishing a CAT reporting relationship with the firm’s CAT Reporting Agent, and certifying data for production.

In Part 2 (to report customer and account data to CAIS), firms should determine whether the firm has accounts associated with Large Trader ID (LTID) and if the firm meets the definition of Small Firm for CAT reporting purposes. Part 2 then lays out the next steps for registering for CAT CAIS, granting entitlement to personnel within the firm, how to submit data to CAT CAIS, establishing a CAT CAIS reporting relationship with the firm’s CAT Reporting Agent, and certifying data for CAIS LTID Production.

A webinar has been scheduled for June 10 at 11:00 a.m. (ET) to review the roadmap.

CAT Roadmap.

CAT Webinar.

©2021 Katten Muchin Rosenman LLPNational Law Review, Volume XI, Number 134
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About this Author

Susan Light, Katten Law Firm, Finance Law Attorney, New York
Partner

Susan Light focuses her practice on financial services regulatory matters. She counsels broker-dealers, hedge funds, investment banks and financial services clients on enforcement issues involving the Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA), other self-regulatory organizations (SROs) and state and federal regulatory authorities. She has particular experience related to sales practice issues, financial and operational issues, anti-money laundering, crowdfunding, cybersecurity, and cryptocurrencies.

...
212-940-8599
Associate

Shelby Kost represents a variety of clients in the financial services industry in a wide range of transactional and corporate matters, advising clients with respect to restructurings, fund formation, mergers and acquisitions, joint ventures, as well as various types of employment, advising and trading agreements.

A background of experience that leads to a wealth of knowledge

While in law school, Shelby served as a lead articles editor for the Loyola University Chicago Law Journal, and represented Loyola University Chicago School of Law at the National Moot Court...

312-902-5444
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