SIFMA published a guide for industry members on the Consolidated Audit Trail ("CAT") reporting requirements.
As previously covered, the SEC adopted Rule 613, which created the CAT to help regulators monitor activity in National Market System securities.
The guide includes a list of key takeaways for industry members, such as (i) which firms and products are subject to CAT, (ii) timelines for CAT implementation, (iii) reportable events, scenarios and fields and (iv) operational considerations, such as architecture, vendors, controls and governance, connectivity and testing.
Additionally, the guide reminds firms to evaluate their CAT preparedness by assessing:
- any technological, regulatory or operational challenges;
- their business continuity, disaster recovery and contingency plans; and
- their compliance with the immediate requirements for CAT (e.g., registration with the Plan Processor, meeting clock synchronization requirements and preparing for connectivity testing in Q3 2019).
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.