Changes to CAT Reporting Timelines Due to COVID Pandemic

The US Securities and Exchange Commission issued an exemptive order last week establishing a new consolidated audit trail reporting timeline for broker-dealers due to the COVID-19 pandemic. It allows for equity and options reporting in phases, taking into account the complexity of reporting events. In order to “address the impact of COVID-19 while preserving progress toward existing milestones,” the order allows for a delayed start to CAT reporting conditional on compliance with certain other obligations such as  milestones related to testing and releases of CAT functionality, as well as all other compliance dates for broker-dealer reporting to CAT.

Broker-dealer reporting on CAT went live on April 13. On March 17, the SEC released a no-action letter saying that due to the pandemic, its staff would not enforce CAT implementation deadlines, the next of which was slated for April 20 when broker-dealers were required to submit data to the CAT on trades they execute on behalf of clients.

The SEC issued a new, phased reporting timeline: June 22, 2020 – initial equities reporting for large broker-dealers and small broker-dealers that currently report to the Financial Industry Regulatory Authority’s Order Audit Trail System; July 20, 2020 – initial options reporting for large broker-dealers; Dec. 13, 2021 – full equities and options reporting for large and small broker-dealers; July 11, 2022 – full customer and account reporting for large and small broker-dealers.