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No, order events occurring prior to an IPO symbol’s inclusion on the CAT Reportable Securities List are not required to be reported to CAT in Phase 2a. In Phase 2a, secondary events that occur after an IPO symbol’s inclusion on the CAT Reportable Securities List that are reported to CAT and are marked unlinked for parent not found will not be considered a CAT Reporting violation if at the time of the parent event, the symbol was not on the CAT Reportable Securities List.

On Wednesday, July 1, 2020 at 10 am ET, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host an industry webinar detailing the upcoming changes to entitlement which will allow users to access the CAT Reporter Portal in only the Test Environment, only the Production Environment or both environments. This webinar is open to all Industry Members and we encourage Super Account Administrators (“SAA”) and CAT Account Administrators (“CAT AA”) to attend.  

Orders received or originated prior to the date on which an Industry Member is required to begin reporting to the CAT and any subsequent events related to such orders, including those occurring on or after the required reporting date, are not required to be reported to the CAT. However, Industry Members may submit to the CAT events related to orders received or originated prior to the required reporting date and they will not be rejected.

Firms that meet the definition of a Small Industry Member and do not report to OATS have a CAT reporting obligation beginning on December 13, 2021, which is simultaneous to the commencement of Phase 2d. As such, Small Industry Members that do not report to OATS and plan to start reporting on December 13, 2021 should code their CAT reporting systems to the Phase 2d CAT Reporting Technical Specifications for Industry Members to be published on June 30, 2020.