Preparing for 2019 CAT Industry Testing
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CAT covers all street-side orders – including all proprietary orders for non-FINRA members.
|Only applicable to FINRA members||Applies to every U.S. registered broker-dealer|
|Does not capture proprietary orders||Clearly deciphers proprietary vs. representative (customerdriven) orders|
|Requires multiple requests to track down representative orders||FDID/CCID links avoid the need for multiple requests to research activity|
Reportable Data & Events
New reportable data and event types will expose resource principal, order activity or aggregated average price order attributes.
|No need to report market making with street-side vs. principal||Eliminates market making exclusions|
|Recording of electronic quotes are limited in scope||Includes OTC equities quoting activity and electronic quotes (exchanges and NMS)|
|Requires only one timestamp on manual events||Requires capture and report of two timestamps on manual events|
Accuracy of Reporting
Firms must have a clear understanding of what they are reporting when the move from OATS to CAT occurs – which may require different approaches.
|Very high compliance rate of more than 99%||Will use FINRA’s surveillance patterns from OATS data|
|High accuracy relied on heavily for FINRA surveillance||Accuracy will rely on achieving the same high compliance rates as OATS|
|Useful for comparing and contrasting with CAT data and surveillance results||Conducting early and frequent testing will drive accurate reporting|