ARTICLE
24 June 2021

FINRA Sets Effective Date For Complete Replacement Of OATS By Consolidated Audit Trail

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Cadwalader, Wickersham & Taft LLP

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FINRA set September 1, 2021 as the effective date for the elimination of the Order Audit Trail System ("OATS") rules.
United States Finance and Banking

FINRA set September 1, 2021 as the effective date for the elimination of the Order Audit Trail System ("OATS") rules.

The designation of the effective date follows FINRA's determination that (i) members are effectively reporting to the Consolidated Audit Trail ("CAT"), and (ii) the accuracy and dependability of the CAT meet the standards outlined in FINRA's 2020 proposed rule change to delete the OATS rules.

In a regulatory notice, FINRA clarified that:

  • firms are still required to report to OATS all order events that take place on or prior to August 31, 2021;
  • OATS will accept reports through September 16, 2021 for order events that take place on or prior to August 31, 2021; and
  • firms must comply with the OATS rules as to events that take place on or prior to August 31, 2021.

FINRA reminded firms that even after the elimination of the OATS rules, FINRA will "continue to monitor for firm compliance with the OATS Rules with respect to order events that occur on or before August 31, 2021."

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