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On April 1, 2021 the Participants of the CAT NMS Plan responded to comment letters in response to the proposed amendment to revise the CAT Reporter Agreement and CAT Reporting Agent Agreement. 

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 Phases 2a/2b/2c. In Phases 2a/2b/2c, 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.

Consolidated Audit Trail, LLC and FINRA CAT, LLC host a Monthly CAT Implementation Update on the third Thursday of every month at 4:15 pm ET. The Monthly CAT Implementation Update meetings provide the industry with a high level overview of materials and guidance published on the www.catnmsplan.com website during the month.

On March 18, 2021, in addition to the regularly scheduled monthly implementation update, staff from FINRA (SRO) will provide an update on the status of OATS retirement.  

Starting in Phases 2a (equities) and 2b (options), 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.

On February 24, 2021 at 3 pm ET, Consolidated Audit Trail, LLC and FINRA CAT, LLC will host an industry webinar to provide a basic overview of the Industry Member Report Cards.

Please note that FINRA CAT, LLC utilizes Zoom to conduct industry webinars. Please check your firewall to ensure your firm has the ability to view Zoom content. If you are unable to download and run Zoom, please click the “join from your browser” link. This webinar will be recorded. The presentation document and recording will be posted.

Consolidated Audit Trail, LLC and FINRA CAT, LLC will host a Monthly CAT Implementation Update on the third Thursday of every month at 4:15 pm ET beginning on September 17, 2020 until further notice. The Monthly CAT Implementation Update meetings provide the industry with a high level overview of materials and guidance published on the www.catnmsplan.com website during the month.

The 2021 Entitlement Certification Period for CAT Reporting Agents (Not Applicable to Industry Members) is scheduled for September 13, 2021 – November 15, 2021. During this period, each organization is required to review and verify all CAT accounts (user, administrator, machine).  

No, primary market transactions, as defined in Section 1.1 of the Plan, are not subject to CAT reporting. The Participants analyzed whether to include primary market transactions in the CAT, and concluded doing so was premature and that such an analysis would benefit from actual experience with the CAT. See Discussion of the Potential Expansion of the Consolidated Audit Trail Pursuant to Section 6.11 of the CAT NMS Plan (May 15, 2017) (available at Expansion Report).

Consolidated Audit Trail, LLC and FINRA CAT, LLC will host a Monthly CAT Implementation Update on the third Thursday of every month at 4:15 pm ET beginning on September 17, 2020 until further notice. The Monthly CAT Implementation Update meetings provide the industry with a high level overview of materials and guidance published on the www.catnmsplan.com website during the month.