The SEC established the Consolidated Audit Trail (the CAT) to enable regulators to track all order and trading activity throughout the U.S. markets for listed equities and options.

While operated by 25 Self-Regulatory Organizations (SROs) including equity and options exchanges, under the supervision of the SEC, the securities industry has undertaken efforts to build and stand up systems necessary to comply with the CAT, working diligently through the coronavirus pandemic and the operational changes, priorities and demands it brought. The transaction database became fully implemented in December 2021.

The SROs and industry are now working on the design and development of the customer database or CAIS which is projected to come online in mid-2022. The data within CAT has become a key regulatory tool as evidenced by the October 2021 SEC staff report on January 2021 market volatility which used CAT data to recreate and analyze the trading activity. Several critical issues remain, most importantly data security and funding. SIFMA has continually voiced concerns about the type and amount of personally identifiable information (PII) data to be reported to and maintained in the CAIS and has repeatedly offered viable alternatives that would serve the same purpose without the attendant data and privacy risk to investors. We continue to engage with the SEC on its August 2020 data security proposal which would, among other things, prohibit the bulk downloading of CAT data and would strictly and clearly prohibit the use of CAT data for any commercial purpose. We continue to advocate for a collaborative, equitable and transparent funding model for the CAT and recommended that the Commission disapprove the proposed model submitted by the SROs.

CAT Reporting Timeline – Key Dates

• March 18-June 27, 2019: Consolidated Audit Trail Registration
• September 30, 2019: Connectivity testing begins
• December 16, 2019: Industry testing begins
• 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
• July 11, 2022: Full customer and account reporting for large and small broker-dealers

See SEC Exemptive Order for Phased Reporting Timelines with Conditional Exemption for Impacts of COVID-19 and the CATNMS Timeline