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The Consolidated Audit Trail (CAT): Unpacking challenges and solutions

William Leahey
William Leahey
Head of Regulatory Compliance, Wealth Management, Refinitiv

The Consolidated Audit Trail (CAT) is a regulatory reporting utility commissioned by the Securities and Exchange Commission (SEC) to enable regulators to more fully track  trading activity and boost transparency; the CAT also heralds significant new obligations and reporting requirements for firms.


  1. The Consolidated Audit Trail is the largest and most comprehensive new regulatory reporting utility in living memory.
  2. Data Hygiene throughout order lifecycle and customer account data is critical to low error, high accuracy CAT reporting.
  3. Industry collaboration among firms, service providers (including Refinitiv) and regulators is critical to a speedy and efficient implementation of CAT over the next three years, with the goal of quickly retiring legacy regulatory reporting systems CAT supersedes.

In response to the May 2010 Flash Crash the SEC adopted Rule 613, and in November 2016 voted approved ‘a national market system (NMS) plan to create a single, comprehensive database known as the consolidated audit trail (CAT). CAT will enable regulators to more efficiently and thoroughly track all trading activity in the U.S. equity and options markets.[1]

At its core, the CAT is a central repository that will receive, consolidate, and retain the trade and order lifecycle data for all NMS securities (i.e., listed equities and options) and over-the-counter equity securities. Importantly, exchanges, Self-Regulatory Organizations (SROs), and broker-dealers are required to submit order lifecycle information to the central repository for each trading day on a nightly basis.[2]  In future phases of CAT, broker dealers are required to submit significant customer account information (e.g., name, address, Large Trader ID, year of birth, etc.).

At its core, the CAT is a central repository that will receive, consolidate, and retain the trade and order lifecycle data for all NMS securities (i.e., listed equities and options) and over-the-counter equity securities. Importantly, exchanges, Self-Regulatory Organizations (SROs), and broker-dealers are required to submit order lifecycle information to the central repository for each trading day on a nightly basis.  In future phases of CAT, broker dealers are required to submit significant customer account information (e.g., name, address, Large Trader ID, year of birth, etc.).

The CAT will have a phased roll-out, with compliance dates for broker dealers beginning in April 2020 and extending to at least mid-2022.  CAT is applicable to all US exchanges and broker dealers and – unlike existing trade reporting utilities (e.g.,OATS) – no US broker-dealers are exempt from CAT requirements.[3]

CAT Industry Implementation Timeline Graphic

CAT has already experienced some delays and challenges. In response, the SEC has proposed amendments to limit further delays and messaged the need for CAT’s timely implementation.[4] As material additional delays are unlikely, firms should take immediate steps to understand exactly what their reporting obligations will be; assess their compliance readiness; and identify any potential challenges relating to the new requirements.

Hands-on support for CAT reporting

The CAT will require firms to report transaction data covering the end-to-end lifecycle of a trade, with specific events and linkages reportable in phases.  Additionally, the CAT will require firms to bulk export certain customer and account information to the CAT; the first such reporting of its kind in US markets.

Standing up new CAT reporting infrastructure and technology is quite an undertaking, atop already significant regulatory reporting workloads.  However, Refinitiv’s BETA suite of solutions is placing CAT priorities front and center to ensure that customers receive the support and advice they need for a smooth transition to seamless compliance.

Our BETA brokerage processing solutions comprise a suite of tools to manage day-to-day brokerage tasks from the back to the front office and integrate seamlessly with existing customer in-house systems. BETA leverages leading-edge technology to simplify processes, boost efficiency and reduce operational costs – and significantly, BETA customers will benefit from innovative CAT reporting support.

A commitment to industry engagement

Refinitiv is an active participant in industry-wide discussions around the CAT (e.g., the Financial Information Forum (FIF), Securities Industry and Financial Market Association (SIFMA)), and we will continue to engage with both decision-makers and industry stakeholders to ensure that we deliver relevant and accurate advice and solutions for firms as they prepare for the many changes embodied within the CAT.  In addition, Will Leahey, Head of Regulatory Compliance for Refinitiv Wealth Management will join a panel of regulators, industry experts, and FINRA CAT senior executives at this year’s SIFMA OPS conference to discuss CAT issues facing Refinitiv customers.

As the wealth industry continues to evolve in the face of tightening regulations and ever-more stringent requirements, Refinitiv remains committed to empowering all stakeholders to optimize and simplify their compliance processes – enabling them to focus on the important strategic decisions that will shape and future-proof their operations.

Our powerful combination of leading-edge technology, reliable data and trusted human expertise uniquely positions us to help you meet the new regulatory requirements of the CAT with confidence, accuracy and efficiency.

Optimize your brokerage processing capabilities with a comprehensive, flexible suite of solutions that seamlessly integrates with your current operations to meet the unique needs of your business.


[1] https://www.sec.gov/news/pressrelease/2016-240.html
[2] https://www.sec.gov/news/pressrelease/2016-240.html
[3] https://www.sifma.org/wp-content/uploads/2019/07/SIFMA-Firms-CAT-Guide.pdf
[4] https://www.lexology.com/library/detail.aspx?g=4b8a10f0-2331-41c8-80ab-dcb58aa022b2