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On March 17, 2020, the SEC issued relief that exempts the Participants from collecting or retaining certain retail customer data, including (1) individual social security numbers or individual tax payer identification numbers; (2) dates of birth and (3) account numbers. Instead, Industry Members would be required to report an account holder’s name, address, and birth year to the CAT.
Consolidated Audit Trail, LLC and FINRA CAT, LLC will host Weekly Industry Testing Checkpoint Calls every Tuesday at 4:15 pm ET beginning on January 7, 2020 through March 17, 2020. The events will be held at 4:15 pm ET.
Please note that FINRA CAT, LLC is now utilizing 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. The presentation document and recording will be posted.Audio file
The Operating Committee of the CAT NMS Plan has issued a statement on the SEC's No Action Letter related to the Consolidated Audit Trail.
On March 16, 2020, the SEC issued a No Action Letter related to Consolidated Audit Trail Reporting.
- Reference Material
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 has retained a Plan Processor to develop and operate the CAT System, and both the Plan Processor and the Participants have policies and procedures for the security and confidentiality of information submitted to the CAT System and access to the information in the CAT Central Repository by Participants.
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.
Only authorized regulatory users from the Participants and the SEC will have permission to access CAT Data via the CAT System. And, only a subset of those authorized regulatory users will have permission to access and view Customer Account Information and Customer Identifying Information, which is stored and handled separately from the order and trade data.