Consolidated Audit Trail (CAT)
Jordan & Jordan’s (J&J) Regulatory Compliance Practice has been tracking the development of CAT since the inception of the requirements and continues to closely monitor developments with respect to the CAT plan and our clients’ CAT implementation strategies. As CAT deadlines continue to evolve, J&J stays up to date on key milestones and implementation requirements. J&J’s focus is to provide our clients the knowledge, resources, and technology to enable a successful CAT implementation. J&J provides a full suite of CAT solutions to assist our clients, including the following:
CAT Subject Matter Expert On-Demand Service
CAT SME On-Demand Service is geared towards firms developing CAT reporting internally or utilizing a vendor that require guidance related to particular use-cases, assistance with supervisory procedures/controls or ongoing monitoring. J&J has the resources available to quickly and competently answer client questions. Typically, answers will be provided to clients within a 24- hour window.
Currently, J&J’s SME’s are providing guidance to numerous broker/dealers on use cases, interpretation, testing and reporting requirements. J&J’s close affiliation with the Financial Information Forum (FIF) has kept us well versed on CAT deadlines and obligations; as such, we regularly provide direction to clients when CAT questions arise.
CAT Reporting Agent (CRA)
J&J is approved by FINRA CAT LLC as an authorized CAT Reporting Agent (CRA) in their production environment.
J&J’s CAT reporting capability will flow through an enhanced version of the Execution Compliance and Surveillance Service (ECS) product. in addition to the daily reporting of events to the FINRA CAT plan processor, ECS will also perform pre-submission testing of data and provide the ability to track and repair post submission rejections. J&J is equipped to handle data provided by clients in multiple formats including FIX, vendor-based and proprietary formats.
CAT Automated Validation Testing
As the timeline indicates, firms will need to perform readiness testing to demonstrate the ability to effectively submit data to CAT. J&J provides regular, independent testing of firms’ CAT reporting to satisfy due diligence and oversight responsibilities. J&J is currently handling this testing for our clients. Clients provide J&J’s ECS with one day’s worth of production data, file submissions and data integrity validations. J&J’s ECS service then performs this testing uninterrupted.
CAT Staff Augmentation Services
J&J staff can provide supplemental CAT resources on-site to help you attain your CAT implementation goals.