CAT Small Firm Onboarding Checklist from FINRA
Is your firm a broker-dealer that is a member of FINRA or a national securities exchange, and receives, originates and/or handles orders in “CAT Eligible Securities”, which includes NMS stocks and Listed Options, and/or OTC Equity Securities? If the answer to this question is yes, then your firm has a Consolidated Audit Trail (CAT) reporting obligation and must register for and obtain access to CAT and prepare for reporting even if your firm plans to rely on a vendor or clearing firm to report equity and/or option transactions on its behalf. There are no exemptions to CAT reporting, unlike OATS. If your firm handles even ONE order in NMS stocks and Listed Options and/or OTC Securities all of the steps on the following checklist apply.
FINRA just released a Small Firm CAT Onboarding Checklist to assist small firms with the onboarding process, deadlines and additional resources. It also includes information on CAT connectivity options, the CAT Reporter Portal, and CAT file transfers.
If you are unsure if any of the steps apply to your firm, please direct your questions to the FINRA CAT Helpdesk at 888-696-3348 or email@example.com. For more detailed information, please refer to the FINRA CAT Industry Member Onboarding Guide.