Archived FAQs

Currently, the Participants are funding the CAT-related costs themselves. The CAT NMS Plan, however, contemplates a funding model in which both Participants and Industry Members contribute to the funding of the CAT. Although the Participants have filed fee filings with the SEC to impose CAT Fees on Participants and Industry Members, the Participants have withdrawn these fee filings at this time. The Participants anticipate filing revised fee filings in the near future.

This FAQ was retired on October 12, 2023.

While SEC Rule 613(a)(3) and Section 6.7(a) of the CAT NMS Plan require that Participants begin reporting to the CAT by November 15, 2017, Industry Members (other than Small Industry Members) begin reporting to the CAT by November 15, 2018, and Small Industry Members begin reporting to the CAT by November 15, 2019, the CAT System currently is not ready to accept data from Industry Members. Although the SEC has not granted an extension to these dates the Operating Committee anticipates that Large Industry Members and Small Industry Members currently reporting to OATS will begin reporting to the CAT in April 2020 and Small Industry Members that are not currently reporting to OATS will begin reporting in December 2021.

This FAQ was retired on May 21, 2020.

If a Reportable Event is priced in a non-U.S. dollar currency, CAT Reporters are required to convert such prices into U.S. dollars based on the conversion rate applicable at the time that the Reportable Event occurred and report the prices in US dollars to the CAT. Although a specific conversion methodology is not prescribed, any methodology must be applied consistently by the Industry Member. The treatment of prices in non-U.S. dollar currencies is consistent with FINRA’s treatment of such prices under OATS reporting requirements (See Compliance FAQ C71 available at: http://www.finra.org/industry/faq-oats-compliance-faq).

This FAQ was retired on September 23, 2020.

For Phase 2c, “if available in the booking system” means that the FDID is either directly available in the booking system, or can be made available through a simple reference data lookup, or can be readily accessed by the booking system through an existing system integration. For example, if the FDID is directly stored or can be directly queried by the booking system, the newOrderFDID field should be populated. In contrast, if, in order to supply the FDID, a new system integration would be required or if new data element(s) were required in the booking record, then the newOrderFDID field would not be required to be populated. It should also be noted that requirements for populating this field may be expanded in future phases of CAT.

This FAQ was retired on July 17, 2020.

No.  As noted in FAQ K4, options assignments and exercises are not orders, as defined by SEC Rule 613, and therefore are not required to be reported to CAT.  Therefore, Industry Members are also not required to report the resulting booking of shares into a customer account resulting from an options assignment or exercise.  Similarly, Industry Members are not required to report the booking of shares or contracts into a customer account resulting from other non-CAT Reportable events (e.g., conversions of a convertible bond into an equity).  As noted in the Industry Member Technical Reporting Specifications, Industry Members may voluntarily report clearing events to CAT that are not required as long as they are properly identified as set forth in the Industry Member Technical Reporting Specifications.

This FAQ was retired on March 9, 2021.

OATS reporting obligations are separate and distinct from CAT reporting obligations, and a firm’s CAT reporting obligation may be different from its OATS reporting obligation. If a firm’s system captures timestamps in nanoseconds, then its CAT events must be reported to nanosecond granularity, even though its OATS submission will only reflect millisecond granularity since OATS does not accept nanoseconds.

This FAQ was retired on November 12, 2021.

In this scenario, Industry Members must populate the orderType as ‘LMT’ and the price as “0”. Refer to FAQ E9 for instructions on orders routed with handlingInstructions that include pricing criteria.

This FAQ was retired on July 1, 2020.

Routes not accepted by the receiving market participant will be required to be reported to CAT beginning in Phase 2c. These routes must be reported with a flag indicating they were not accepted by the receiving market center.

This FAQ was retired on August 27, 2020.

The Order Route Event for orders routed as Stop orders should include an OrderType of either market or limit and a handling instruction of STOP or other appropriate handling instruction as applicable. 

This FAQ was retired on July 1, 2020.

If an order is received/originated or routed without a specific limit price but includes handlingInstructions that may include certain pricing criteria, such as a ‘PEG’ or options related order, the orderType field may be populated as either ‘MKT’, or ‘LMT’ with a price of ‘0’. The ‘PEG’ or other instruction must be included in the handlingInstructions field on the event. If an order is not a market order but is received or originated without a specific limit price and does not have handlingInstructions that include pricing criteria, such as an order that is originated to represent multiple customer orders but does not have a set limit price, the orderType field must be populated as ‘LMT’ and the price must be ‘0’.

This guidance does not apply to Stop or Stop Limit orders - refer to FAQ B57 for additional information on the orderType field for Stop, Stop Limit, Stop on Quote, Stop Limit on Quote, Trailing Stop, and Trailing Stop Limit orders.
 

This FAQ was retired on July 1, 2020.

Members that have either facilitated a basket trade or crossed two customers’ baskets and submitted the information to NYSE’s Crossing Session II, should report these transactions to CAT as a Trade Event. The event timestamp reported to CAT should be the time the member crossed or facilitated the basket and not the acknowledgment time received back from NYSE. Further, the Trade event must contain the marketCenterID of “N” to designate the New York Stock Exchange and the tapeTradeID should be populated with “NYSE CS2” to denote the transaction was reported to the Crossing Session II.

This FAQ was retired on July 3, 2024.

The CAT NMS Plan requires the Plan Processor, subject to the oversight of the Operating Committee, to develop a comprehensive information security program that addresses the security and confidentiality of all information accessible from the CAT and the operational risks associated with accessing the CAT. Appendix D of the CAT NMS Plan sets forth minimum data security requirements for the CAT that the Plan Processor must meet. In addition, as required by the Plan, the Plan Processor has designated a Chief Information Security Officer (CISO), who is responsible for, among other things, creating and enforcing appropriate policies, procedures, and control structures regarding data security.

This FAQ was retired on January 29, 2025.

Yes, the CAT is considered an SCI System and it must be operated in compliance with the requirements in Reg SCI applicable to an SCI System. In addition, the CAT NMS Plan requires the Technical Specifications to satisfy all applicable regulations regarding database security including provisions of Reg SCI.

This FAQ was retired on January 29, 2025.

The Consolidated Audit Trail, or “CAT,” is being developed by the national securities exchanges – BOX Exchange LLC, Cboe BYX Exchange, Inc., Cboe BZX Exchange, Inc., Cboe EDGA Exchange, Inc., Cboe EDGX Exchange, Inc., Cboe C2 Exchange, Inc., Cboe Exchange, Inc., Investors’ Exchange LLC, Long-Term Stock Exchange, Inc., Miami International Securities Exchange LLC, MIAX Emerald, LLC, MIAX PEARL, LLC, NASDAQ BX, Inc., Nasdaq GEMX, LLC, Nasdaq ISE, LLC, Nasdaq MRX, LLC, NASDAQ PHLX LLC, The NASDAQ Stock Market LLC, New York Stock Exchange LLC, NYSE American LLC, NYSE Arca, Inc., NYSE Chicago, Inc. and NYSE National, Inc. – and the Financial Industry Regulatory Authority (“FINRA”), a national securities association (collectively, the “Participants”), pursuant to SEC Rule 613. Consolidated Audit Trail, LLC (“CATLLC”) is the entity organized by the Participants to create, implement and maintain the CAT. Broker-dealers (called “Industry Members” under the CAT NMS Plan), exchanges and FINRA will be required to submit customer, order and trade information in “NMS Securities” (i.e., exchange listed stocks and options) and “OTC Equity Securities” (i.e., over-the-counter stocks), across all markets to the CAT Central Repository. The system is designed to permit the SEC and Participants to more effectively and efficiently regulate the securities markets.

This FAQ was retired on January 29, 2025.

Pursuant to the CAT NMS Plan, Customer Account Information generally includes, account number, account type, customer type, date account opened, and large trader identifier (if applicable). Customer Identifying Information means information of sufficient detail to identify a customer. The CAT NMS Plan currently requires that if the customer is an individual, the Customer Identifying Information includes the individual’s name, address, date of birth, individual tax payer identification number/social security number, and individual’s role in the account (e.g., primary holder, joint holder, guardian, trustee person with the power of attorney). If the customer is a legal entity, the Customer Identifying Information includes the legal entity’s name, address, Employer Identification Number/Legal Entity Identifier (“LEI”) or other comparable common entity identifier (if applicable), provided, however, that an Industry Member that has an LEI for a customer must submit the customer’s LEI in addition to other information of sufficient detail to identify a customer. As discussed below in FAQ S7, the Participants requested an exemption from the SEC from certain provisions of the CAT NMS Plan so that social security numbers/taxpayer identification numbers, dates of birth and account numbers of individual customers would not be reported to the CAT Central Repository.

This FAQ was retired on January 29, 2025.

The Participants requested an exemption from the SEC from certain provisions of the CAT NMS Plan so that social security numbers/taxpayer identification numbers for natural persons would not be reported to the CAT. If the exemption is granted, the Plan Processor will generate a unique CAT Customer ID (“CCID”) using a strategy developed in collaboration with Industry Members. The CCID strategy uses a two-phase transformation that avoids the receipt or retention of social security numbers or individual taxpayer identification numbers in the CAT. Industry Members will not receive the generated CCID. The resultant CCID and an associated Firm Designated ID (“FDID”) will be stored by the Plan Processor for further processing. As noted above, the Participants requested an exemption from the SEC from certain provisions of the CAT NMS Plan so that the dates of birth and account numbers of individual customers would not be reported to the CAT Central Repository. Instead of reporting dates of birth and account numbers for individuals, Industry Members would report to the CAT years of birth and FDIDs for accounts for individuals.  

This FAQ was retired on January 29, 2025.

The CAT NMS Plan states that the Plan Processor must provide Participants’ regulatory staff and the SEC with access to all CAT Data for regulatory purposes only. The CAT NMS Plan also states that Participants’ regulatory staff and the SEC will access CAT Data to perform functions, including economic analyses, market structure analyses, market surveillance, investigations, and examinations. Under the CAT NMS Plan, Participants are required to implement effective information barriers between their regulatory and non-regulatory staff with regard to access and use of CAT Data stored in the Central Repository, and Participants may not use CAT Data for commercial purposes. However, the CAT NMS Plan provides that a Participant will be permitted to use the data that it reports to the CAT System for any lawful purpose, including commercial purposes (e.g., to develop new order types).

This FAQ was retired on January 29, 2025.

CATLLC’s actions in the event of unauthorized access to CAT Data will depend on the circumstances. If CATLLC becomes aware of actual (or potential) unauthorized access to CAT Data, CATLLC, working with the Plan Processor, will take all reasonable steps to investigate the incident, mitigate potential harm from the unauthorized access and protect the integrity of the CAT System. CATLLC also will report unauthorized access to law enforcement, the SEC and other authorities as required or as it deems appropriate. CATLLC will notify other parties of unauthorized access to CAT Data where required by law and as it otherwise deems appropriate. CAT LLC will maintain insurance that is required by law. Additionally, the Plan Processor maintains certain insurance.

This FAQ was retired on January 29, 2025.

A firm may file a fee dispute by submitting a written application to the FINRA CAT Helpdesk at [email protected] within 15 business days after being notified of such disputed CAT fees. The application is required to identify the disputed CAT fees, state the specific reasons why the applicant takes exception to such CAT fees, and set forth the relief sought. FINRA CAT will forward all fee dispute applications to CATLLC. For more information on fee dispute resolution procedures, please see the “CAT Compliance Rule” provisions on fee dispute resolution that are set out in each of the Participants’ rulebooks (e.g. FINRA Rule 6898).

This FAQ was retired on October 28, 2024.