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SEC Provides for Phased CAT Broker-Dealer Reporting Timelines
Friday, April 24, 2020

On April 20, the Securities and Exchange Commission issued two orders relating to the implementation of the Consolidated Audit Trail (CAT) to address the impact of COVID-19. In the first order, the SEC allowed broker-dealers to establish a phased CAT reporting timeline, subject to certain conditions. In its second order, the SEC permitted certain introducing brokers to follow the small broker-dealer reporting timeline.

The reporting milestones now applicable to broker-dealers include the following:

  • 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; and

  • July 11, 2022: Full customer and account reporting for large and small broker-dealers.

More information regarding the phased CAT reporting timelines is available here.

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