On April 20, the Securities and Exchange Commission issued two orders relating to the implementation of the Consolidated Audit Trail (CAT) to address the impact of COVID-19. In the first order, the SEC allowed broker-dealers to establish a phased CAT reporting timeline, subject to certain conditions. In its second order, the SEC permitted certain introducing brokers to follow the small broker-dealer reporting timeline.

The reporting milestones now applicable to broker-dealers include the following:

  • June 22, 2020: Initial equities reporting for large broker-dealers and small broker-dealers that currently report to FINRA’s Order Audit Trail System (OATS);
  • July 20, 2020: Initial options reporting for large broker-dealers;
  • Dec. 13, 2021: Full equities and options reporting for large and small broker-dealers; and
  • July 11, 2022: Full customer and account reporting for large and small broker-dealers.

More information regarding the phased CAT reporting timelines is available here.