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On February 1, the Financial Industry Regulatory Authority (FINRA) published its 2021 Report on FINRA’s Examination and Risk Monitoring Program (Report). The annual Report summarizes various findings and observations from recent FINRA examinations of its member firms on a range of topics and notes certain areas of the future focus of FINRA examinations in 2021.
Continue Reading 2021 Report on FINRA’s Examination and Risk Monitoring Program

On August 26, the Securities and Exchange Commission published notice in the Federal Register regarding proposed rule changes that the Financial Industry Regulatory Authority (FINRA) had filed with the SEC. The changes would delete the order audit trail system (OATS) rules in the FINRA Rule 7400 Series and FINRA Rule 4554 once FINRA members are…

On May 15, the Securities and Exchange Commission adopted amendments to the national market system plan governing the consolidated audit trail (the CAT NMS Plan). The Financial Industry Regulatory Authority (FINRA) and the national securities exchanges that are CAT NMS Plan participants (the Participants) are now required to publish and file with the SEC a…

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.
Continue Reading SEC Provides for Phased CAT Broker-Dealer Reporting Timelines

On May 21, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 19-19 (Notice), which reminds applicable member firms that they must register with FINRA CAT, LLC (FINRA CAT) on or before June 27 for purposes of reporting to the Consolidated Audit Trail (CAT). This reporting requirement relates to 1) member firms or national securities exchanges that handle orders or quotes in National Market System (NMS) stocks, over-the-counter equity securities or exchange listed options (each, an Industry Member); and 2) third-party CAT reporting agents that are or will be authorized to submit data to the CAT on behalf of an Industry Member. The CAT rules do not provide for any firms to be excluded or exempted from this reporting requirement.
Continue Reading FINRA Issues Regulatory Notice Reminding Member Firms about CAT Reporting Deadlines

On August 27, the Securities and Exchange Commission’s Division of Trading and Markets issued a public statement on the status of the consolidated audit trail (CAT) and the SROs’ (defined below) currently expected timetable for compliance with their obligations under the revised Plan (defined below).
Continue Reading Statement on Status of the Consolidated Audit Trail