The Consolidated Audit Trail (CAT) is coming. And soon.
The much anticipated and awaited securities audit trail that is being billed as a means to help monitor and police stock market trading will begin operation for file submission in April.
Here is the official Finra timeline:
| 2a Equities | Large Industry Members and Small Industry Members that are OATS Reporters | Test Environment opens for file submission and data integrity validations | December 16, 2019 |
| Large Industry Members and Small Industry Members that are OATS Reporters | Production Environment Go-Live for file submission and data integrity validations | April 20, 2020 | |
| Large Industry Members and Small Industry Members that are OATS Reporters | Test Environment opens for Intra-firm Linkage validations | April 20, 2020 | |
| Large Industry Members and Small Industry Members that are OATS Reporters | Production Environment Go-Live for Intra-firm Linkage validations | July 27, 2020 | |
| Large Industry Members and Small Industry Members that are OATS Reporters | Test Environment opens for Firm to Firm Linkage validations | July 27, 2020 | |
| Large Industry Members and Small Industry Members that are OATS Reporters | Production Environment Go-Live for Firm to Firm Linkage validations | October 26, 2020 | |
| Large Industry Members and Small Industry Members that are OATS Reporters | Test Environment opens for Exchange and TRF Linkage validations | September 9, 2020 | |
| Large Industry Members and Small Industry Members that are OATS Reporters | Production Environment Go-Live for Exchange and TRF Linkage validations | October 26, 2020 |
Years in the making, CAT is expected to fill multiple needs for myriad market participants but many questions linger. Is it enough? Is it worth the cost?
Peter Gargone, n-Tier Founder and Chief Executive Officer sat down with Traders Magazine’s Editor John D’Antona Jr. and spoke about the aforementioned issues as well as offered his opinions.
TRADERS MAGAZINE: What are some of the main issues brokers have faced in meeting the CAT deadline? Technology? Security?
Peter Gargone: Security and liability for potential security breaches are an ongoing concern for brokers ahead of the CAT deadline. Brokers are working to ensure there are robust operational and technical processes in place to monitor and manage the reporting accuracy. Successfully implementing a technological solution that can handle the volumes of exceptions and corrections expected to result from the rollout of CAT is also top of mind. In CAT’s latter phases, brokers remain concerned about the occurrence of rejects from cross- firm data linkage.
TM: Can the CAT be the answer the SEC wants or envisioned? Or does it fall short?
Gargone: It is still to be determined whether CAT will satisfy the SEC’s particular requirements. As an overall initiative CAT will undoubtedly provide a more complete and accurate view of activities in the market. Still, the value provided by this additional data will depend on the level of data accuracy and data quality achieved by the industry.
TM: What has the technology spend been like for the industry or brokers? – More than thought? Less? Can it be recouped?
Gargone: We feel most firms have budgeted appropriately for the CAT initiative. However, when firms look at the overall spend across different regulatory requirements, both domestic and international, the costs are continually rising. For firms that take a holistic approach to regulatory operations and data accuracy, we believe the regulatory risk and operational efficiencies gained by now having complete and accurate data will allow firms to recoup some of that overall spend.
TM: When it comes to the CAT – will this be the final version? Or will there be a CAT 2.0 as glitches arise?
Gargone: As with any complex regulation we would expect a period of adjustments and clarifications. This has undoubtedly been the case with predecessor regulations such as OATS, EBS, and LOPR, which have undergone many years’ worth of changes based on industry feedback.
