Consolidated Audit Trail (CAT)

Regulatory Obligations

FINRA and the national securities exchanges have adopted rules requiring their members to comply with SEA Rule 613 and the CAT NMS Plan, which cover reporting to the CAT; clock synchronization; time stamps; connectivity and data transmission; development and testing; recordkeeping; and timeliness, accuracy and completeness of data requirements.

Regulatory Notice 20-31 (FINRA Reminds Firms of Their Supervisory Responsibilities Relating to CAT) notes that firms’ WSPs also must be reasonably designed to ensure that the data reported by them or on their behalf is transmitted in a timely fashion and that it is complete and accurate.

Findings and Effective Practices

Findings

  • Incomplete Submission of Reportable Events: Failing to report certain Reportable Events, as defined by CAT, in a timely manner to the Central Repository (e.g., new order events, route events, execution events).
  • Failure to Repair Errors Timely: Not repairing errors by the T+3 correction deadline.
  • Failure to Submit Corrections: Not submitting corrections for previously inaccurately reported data, including data that did not generate error feedback from CAT. 
  • Inaccurate or Incomplete Reporting of CAT Orders: Submitting information that was incorrect, incomplete or both to the Central Repository.
  • Unreasonable Supervision:
    • Not establishing and maintaining reasonable WSPs or supervisory controls regarding CAT reporting and clock synchronization that are performed by the firm, third-party vendors, or both.
    • Not implementing an accuracy review (as described in Regulatory Notice 20-31 (FINRA Reminds Firms of Their Supervisory Responsibilities Relating to CAT)).
    • Not using a reasonable sample size when selecting firm CAT reports for review.
    • Not supervising Reporting Agents that report to CAT on the firm’s behalf.
    • Not promptly remediating CAT reporting issues when brought to the firm’s attention either through its own reviews or regulatory inquiries from FINRA.
  • Recordkeeping: Not maintaining underlying books and records to support transactional data reported to CAT. 

Effective Practices

  • Mapping Internal Records to CAT-Reported Data: Maintaining a “map” that shows how the firm’s internal records and blotters correspond to various fields reported to CAT.
  • Archiving CAT Feedback: Archiving CAT feedback within a 90-day window so that firms can submit corrections, if necessary.
  • CAT Supervision: Implementing WSPs requiring a comparative review of CAT submissions versus firm order and trade records (including for firms that rely on third-party submitters), conducting a daily review of the CAT Reporter Portal, regardless of the error rate percentage; utilizing CAT Report Cards and CAT FAQs to design an effective and reasonable supervision process; and, when relying on a CAT reporting agent, maintaining a written agreement that specifies the respective functions and responsibilities for exception management and error correction. 
  • CAT Clock Synchronization: When relying on third-party, non-broker-dealer vendors for synchronization of business clocks, obtaining synchronization logs daily from such parties and reviewing them to ensure that the clock drifts are within acceptable thresholds (i.e., 50 milliseconds).1
  • Customer and Account Information System (CAIS) Supervision: Establishing reasonable supervisory processes and procedures that address, for example:
    • monitoring both the CAIS Reporter Portal and CAIS notifications for data formatting and inconsistencies;
    • monitoring that customer and account information is reported in an appropriately secure manner pursuant to CAT reporting requirements (e.g., customer input identifiers are not submitted to CAT or CAIS unless they have been properly transformed into a “hashed” Transformed Input ID (TID) prior to submission; customer account identifiers (FDIDs) do not reflect actual account numbers);
    • confirming that CAIS data is consistent with prior submissions for the same customer; and 
    • repairing CAIS inconsistencies within the required time period (i.e., no later than 5 p.m. ET on the third CAT Trading Day after the Customer or Account Information became available to the firm). 
  • Self-Reporting: When your firm discovers CAT reporting issues, self-reporting them via the appropriate form (available in the Forms section of the CAT NMS Plan website) or through the FINRA CAT Help Desk.

CAIS Reporting Obligations UPDATED FOR 2025

Additional Resources

Data Integrity and Timeliness Issues in Municipal Underwriting Filings

  • MSRB Rule G-32 (Disclosures In Connection With Primary Offerings) requires municipal underwriters to provide certain data about primary offerings of municipal securities (e.g., offering type, issuer name and description, security information, type of disclosure document, continuing disclosure information) to the Municipal Securities Rulemaking Board’s (MSRB) Electronic Municipal Market Access (EMMA)2 system within specific timeframes. 
  • Firms that act as a lead or sole underwriter of municipal securities offerings may consider these common issues concerning the accurate, complete and timely submission of Form G-32 data when evaluating their related supervisory processes and procedures:
    • not submitting Form G-32 data within the timeframes required by MSRB Rule G-32(b)(i)(A);
    • submitting inaccurate data (e.g., formal award time and date, retail order period indicator);
    • submitting data in incorrect fields (e.g., inaccurately reporting that both issuers and obligors had entered into continuing disclosure agreements);
    • submitting inaccurate offering dates and times of first execution for remarketings that are considered “new money;”
    • omitting names of key stakeholders (e.g., syndicate members, municipal advisors);
    • not correctly identifying advance refundings;
    • not correctly identifying limited offerings exempt from SEA Rule 15c2-12; and
    • not checking data prepopulated from the New Issue Information and Dissemination Service (NIIDS) for accuracy and completeness.3
  • Effective practices for reporting Form G-32 data include:
    • requiring supervisory review of all Form G-32 data prior to submission (including the prepopulated data from NIIDS);
    • periodically reviewing prior data submissions to identify potential areas for improvement;
    • maintaining a documented process for making timely and accurate Form G-32 data submissions; and
    • training firm personnel on Form G-32 submission requirements, timeframes and terminology (including the use of EMMA’s Dataport system).
  • For additional guidance concerning Form G-32 data integrity, please see the MSRB’s Frequently Asked Questions About Form G-32 and the EMMA Document Submission page.
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Customer Order Handling: Best Execution and Order Routing Disclosures

1 See Regulatory Notice 20-31 (FINRA Reminds Firms of Their Supervisory Responsibilities Relating to CAT).

2 EMMA stands for Electronic Municipal Market Access and is the official source for municipal securities data and documents.

3 For offerings that are made depository-eligible via DTCC’s New Issue Information Dissemination Service (NIIDS), certain information entered into NIIDS flows directly into Form G-32 and will be pre-populated.