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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. 

On March 16, 2020, the SEC issued a No Action Letter related to Consolidated Audit Trail Reporting.

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.

Industry Members are required to obtain and report LTIDs to CAT for Firm Designated IDs (FDID) with Reportable Events that must be reported to CAT in Phase 2c (equities) and Phase 2d (options). This applies to both existing FDIDs and new FDIDs established after the Phase 2c and 2d implementation dates. Each Industry Member must determine how to obtain the LTID for each FDID – to the extent that an LTID exists – in order to report this information to CAT.

OTC Link trade negotiation messages directed by an OTC Link ATS subscriber to a Global OTC quote meet the definition of an order. Because an immediately actionable order is sent to Global OTC as the result of an OTC Link message, the OTC Link ATS subscriber must report the order and route to Global OTC, even if the order is not ultimately executed.

When an employee of the Industry Member is exercising discretion over multiple client accounts and creates an aggregated order for which a trading account number of the Industry Member is not available at the time of order origination, the FDID can be populated by the Entity ID instead of the identifier for an account number. An Entity ID is an identifier of the Industry Member that represents the firm discretionary relationship with the client rather than a firm trading account.

In Phases 2a or 2b, events subsequent to an internal route modification may be populated with any orderID that allows the event to be linked to the order lifecycle. For example, an order that was internally routed from a sales desk to a trading desk is subsequently modified at both the sales and trading desks, and ultimately executed at the trading desk. The sales desk and trading desk maintain different orderIDs. In this example, in Phase 2a the orderID on the related Trade event may link to either the MEIR reported by the trading desk or the MEOM reported by the sales desk.

In Phase 2b, the Industry Member may populate any of the side values applicable to sell orders (i.e., SL, SS, SX). A new value applicable to options sell orders will be added for Phase 2d. 

Proprietary orders that are simultaneously entered into an OMS/EMS upon origination are always considered electronic. However, in Phase 2b it will be acceptable to report such events as either manual or electronic. Therefore, if an Industry Member has interpreted proprietary options orders manually entered into an OMS/EMS as manual events for Phase 2b, it will be acceptable to treat such events as manual in Phase 2b. Accordingly, if a proprietary order is routed electronically and the Order Route event is reported in Phase 2b, the priorUnlinked flag must be populated.

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, In