The SEC issued Orders granting exemptive relief (see here and here) to support the implementation of the Consolidated Audit Trail ("CAT").
In the first Order, the SEC pushed back certain CAT implementation deadlines for equities and options reporting in light of the COVID-19 pandemic. In the second Order, the SEC permitted certain introducing brokers with less than $500,000 in total capital (i.e., those brokers that meet the net capital requirements for small broker-dealers under Rule 0-10(c)(1) of the Securities Exchange Act of 1934) to be treated as small broker-dealers for purposes of the CAT.
The SEC set the following CAT reporting dates:
- June 22, 2020: Initial phase-in of equities reporting for large broker-dealers and small broker-dealers reporting to FINRA's Order Audit Trail System;
- July 20, 2020: Initial phase-in of options reporting for large broker-dealers;
- December 13, 2021: Full coverage of equities and options reporting for large and small broker-dealers; and
- July 11, 2022: Full coverage of customer and account reporting for large and small broker-dealers.
Primary Sources
- SEC Press Release: SEC Provides for Phased CAT Broker-Dealer Reporting Timelines with Conditional Exemption for Impacts of COVID-19
- SEC Order Granting Conditional Exemptive Relief: Release No. 34-88702
- SEC Order Granting Conditional Exemptive Relief: Release No. 34-88703
Originally published April 21, 2020
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