In a comment letter to the Consolidated Audit Trail ("CAT") Leadership Committee, the Financial Information Forum ("FIF") recommended several "logistical changes to the specification" as the Consolidated Audit Trail transitions to a new Plan Processor.

The FIF urged the self-regulatory organizations to focus on:

  • the integration of an "Error Correctional Tool that will help facilitate the CAT error repair process in an efficient and timely manner";
  • the continued review and solution of "specification-related issues" identified by industry members, including, but not limited to: (i) "finalizing FDID guidance," (ii) "clarification of the CAT registration," (iii) "Negotiated Trade/Trade," (iv) "Metadata file layout," (v) "defined scope and logistics of the industry testing period," (vi) "guidance around cybersecurity protocols," and (vii) "final resolution of all specification-related issues raised" by industry members;
  • the facilitation of a process that will permit CAT Reporters to receive guidance related to interpretive and technical questions regarding CAT implementation in a timely manner; and
  • the development of a functioning "production-quality test environment during the initial roll-out of the CAT testing phase."

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