Consolidated Audit Trail (“CAT”): Technical Specifications for Industry Members Draft Released
Late yesterday, the CAT Plan Processor, Thesys CAT, released their initial draft of the Industry Member technical specification for the reporting of order data pursuant to the CAT NMS Plan. Thesys CAT will continue meeting with industry members to discuss the initial draft specification and issue a second draft in late October, followed by the final version no later than November 15, 2017. As a reminder, industry members are required to begin reporting order data to the CAT by November 15, 2018. Exchanges will begin reporting to CAT by November 15, 2017. The initial draft technical specification contains several significant, additional requirements that were not detailed in the original CAT NMS Plan including the following:
- The draft specification contains a proposed requirement to report all Execution Assignments, which are separate and apart from the reporting of post trade allocations. This would apply to all orders not only instances of representative orders, bunched orders, etc. This includes creating assignment IDs as unique identifiers for each assignment.
- Separate reporting requirements for post trade allocations. Allocation reports would even be required in those instances when the Firm Designated ID of the customer is reflected on the initial order. The CAT NMS Plan did call for the reporting of allocations, however, the industry had hoped that allocation reports would not be required if the Firm Designated ID of the ultimate customer was reflected on the order record. Additionally, firms will be required to identify the firm(s) from which allocation instructions were received.
- The concept of an Order Accepted event was introduced in the spec for orders received from another broker
- The spec contemplates only two formats for the reporting of CAT information, JSON and CSV. Early on, indications were that the plan processor would accept multiple industry recognized formats, such as FIX.
- Specific detail with respect to reporting for options, including option market maker quotes, complex options, CMTA reporting and Options Open Outcry/Floor Trading
Please contact us with any questions or if you would like to hear how Jordan & Jordan can assist your firm in preparing for CAT compliance.
Managing Director, Compliance Services