CAT Production Deadline Extended

March 18th | 2020

Due to the impact of COVID-19, the SEC recently issued a no-action letter related to the Consolidated Audit Trail (“CAT”), which effectively extends the deadline to comply from April 20, to May 20, 2020. The CAT will track orders throughout their life cycle and identify the broker-dealers handling them, thus allowing regulators to more efficiently track activity throughout the U.S. markets.

Be aware, however, that there is a production readiness testing process that must be completed before Industry Members can submit production data to the CAT. Previously, FINRA CAT, the administrator of the CAT, has indicated that a roughly two-week lead time was needed; so access to production for April 20 could not be guaranteed if production readiness testing was not completed by April 6. So, although the deadline is now May 20, as a practical matter, Industry Members should aim to pass production readiness testing process well before then.

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