CAT Reporting Readiness: Key Takeaways for Consolidated Audit Trail (CAT) Compliance
You'll often see references to "Finra CAT." This reflects FINRA's key role in the CAT ecosystem, including setting reporting standards, managing the reporting environment, and supporting regulatory oversight.
Firms that embed CAT compliance into their workflows benefit from fewer errors, lower long-term costs, and a stronger control environment. At CMS, we help firms shift CAT from a regulatory burden to a competitive strength.
a. Reporting obligations and scope Industry members must comply with the CAT NMS Plan and FINRA CAT rules. This includes reporting order events (entry, modification, cancellation, execution) and customer/account data through CAIS. b. Clock synchronization and timestamping Precise timestamps and synchronized clocks are foundational. Even small timing discrepancies can generate audit-trail breaks and regulatory attention. c. Data completeness, accuracy and review Firms must maintain clear responsibilities, review cycles, exception-handling processes, and documented procedures for validating CAT submissions. Regulators expect evidence of these controls. https://capmarketsolutions.com/ d. Connectivity, transmission and infrastructure Reliable connectivity to the CAT reporting portal (or a reporting agent) is essential. Firms must monitor submission quality, latency, errors, and reconciliation activity. e. Governance, oversight and documentation Written Supervisory Procedures (WSPs) must fully reflect CAT obligations, including review schedules, supervisory controls and audit-trail documentation. FINRA places strong emphasis on internal oversight and self-testing. End
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