Consolidated Audit Trail (CAT)

On November 15, 2016, the SEC approved the National Market System Plan governing the Consolidated Audit Trail “(CAT”). The SEC took the first step in the implementation phase by formally naming Thesys Technologies, LLC as the Plan Processor for the CAT. Among other things, the Plan Processor is responsible for: 1) operating, maintaining, and upgrading the central repository; 2) ensuring the security and confidentiality of all data reported to the central repository; and 3) publishing technical specifications containing detailed instructions for the submission of data by the self-regulatory organizations (SROs) and broker-dealers to the central repository. This is the first step in the two-year process, at the end of which most broker-dealers, except small broker-dealers, will be required to submit data to the central repository.

Jordan & Jordan (J&J) is closely monitoring developments with respect to the CAT plan. J&J’s focus is to provide our clients the knowledge, resources and technology to drive change within an organization. The following are areas where J&J can assist with CAT planning:

  • Information Resource – J&J’s close affiliation with the Financial Information Forum (FIF) has kept us well versed on CAT milestones; as such, we can provide a CAT Regulation overview and highlight implications specific to each firm
  • Readiness Assessment – J&J can perform a review of your current order/trade reporting infrastructure through an assessment of the current OATS and/or EBS reporting environment to verify the systems, processes and procedures meet current requirements; such an assessment can also be utilized to identify the systems, data and processes that will be necessary for a successful CAT implementation
  • Staff Augmentation – Perhaps you have the implementation plan but you lack the available resources; J&J has experienced industry professionals who can help you attain your CAT project goals
  • Technology Solutions – J&J can evaluate solution providers so firms make informed decisions on technology solutions and emerging technologies

J&J CAT Implementation Services

Depending upon the needs of your firm, J&J can provide varying levels of assistance as you prepare for the implementation of CAT.  First, J&J can help prepare your customer data for reporting to the Plan Processor by conducting a thorough review of customer master files and data sources to ensure the firm’s records are comprehensive, consistent across different systems and contain all required data points for reporting.  This includes preparation for the associated reporting of firm designated IDs.  More generally, J&J can perform a readiness assessment to identify particular areas requiring attention as the firm prepares to implement the requirements of CAT.  This includes orders, executions, routes, and allocations for all of the CAT reportable asset classes.  Finally, J&J staff can supplement your project management staff or manage the CAT implementation project at your firm. We will identify departments and staff for the project team, assign responsibilities, schedule testing, and track progress through to implementation.