Announcements

CAT LLC is pleased that the funding model has been approved by the SEC, following an extensive rulemaking process. From the outset, Exchange Act Rule 613 contemplated that both the Plan Participants and Industry Members would fund the CAT. Nonetheless, the Plan Participants have been funding the CAT in full since its inception. With approval of the funding model, the Commission’s original Rule 613 requirements regarding how the CAT would be funded can now be realized.

The 2023 User Accounts Entitlement Certification Period for CAT Reporting Agents (not applicable to Industry Members) is September 11, 2023 – November 13, 2023. 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.

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. 

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.

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.

As previously communicated, Industry Members must complete an annual certification for Business Clock Synchronization by March 15th of each year.

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, 2023

In addition: