As previously announced, the last two Industry Member Compliance deadlines noted in CAT Alert 2022-01, Interim Reporting Obligation 4 and Full CAIS Compliance Go-Live, have been delayed to future dates. The new deadlines will be announced no later than August 15, 2023 and will not be before the fourth quarter of 2023. The new deadlines will include sufficient time for Industry Members to correct errors once known issues that could impact their CAT reporting compliance obligations have been addressed. Additional information will be provided in an updated CAT Alert when available.
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FINRA’s User Accounts Certification Process for Super Account Administrators (SAAs) is scheduled for April 17 – June 19, 2023. During this period, SAAs for CAT Firms with one or more user and/or administrator accounts must certify that authorized users are only entitled to those privileges necessary to perform their job responsibilities on the FINRA Entitlement Platform or remove access if no longer required.
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The last two Industry Member Compliance dates noted in CAT Alert 2022-01, Interim Reporting Obligation 4 and Full CAIS Compliance Go-Live, currently March 10 and March 17 respectively, will be moved to future dates to be announced shortly. The new dates are not anticipated to be before the second half of 2023 and will include sufficient time for Industry Members to correct errors once known issues that could impact their CAT reporting compliance obligations have been sufficiently remediated. Additional information will be provided in an updated CAT Alert when available.
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As previously communicated, Industry Members must complete an annual certification for Business Clock Synchronization by March 15th of each year.
UPDATED A copy of the certification form is available here .
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The Interim Reporting Obligation Schedule set forth in CAT Alert 2022-01 is being updated as follows:
Interim Obligation 1 – No change
Interim Obligation 2 – No change
Interim Obligation 3 – No change
Interim Obligation 4 – Moved from December 5, 2022 to March 10, 2023
Full Compliance Go-Live – Moved from December 12, 2022 to March 17, 2023In addition:
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The 2022 User Accounts Entitlement Certification Period for CAT Reporting Agents (not applicable to Industry Members) is September 12, 2022 – November 14, 2022. During this period, a Certification Representative (CRep) for each organization must certify that accounts with access to CAT applications, data and tools are valid and users are entitled only to the entitlements (privileges) necessary to perform their current job responsibilities.
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The Participants have determined to delay the full Customer Account Information System (“CAIS”) compliance deadline from July 11, 2022, to December 12, 2022. This extension of the compliance deadline will assist in addressing reporting challenges and delays in error feedback and processing, and will allow time for such issues to be remediated. The CAIS testing environment has been available since January 31, 2022, and the production environment has been available since April 25, 2022.
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Please see the attachment to view the Consolidated Audit Trail, LLC's 2022 Financial and Operating Budget.