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.