SEC Chair Jay Clayton Rejects Request By Exchanges To Delay CAT Reporting Implementation

The SEC will not delay the implementation of the Consolidated Audit Trail ("CAT"). Exchanges are required to begin compliance with the first reporting phase on November 15, 2017. Chair Jay Clayton rejected the last-minute request from several major exchanges to delay the exchanges' reporting requirement by a year to November 15, 2018 (among other requests to delay the phased-in implementation of the CAT requirements for industry participants).

The exchanges requested additional delay, arguing that they spent "considerable time and resources to develop and implement the CAT." They said that ongoing cybersecurity concerns, including the recent Equifax breach, have raised complex issues regarding the ability to adequately address security policies, procedures, plans and controls to ensure a level of cybersecurity protection that is necessary in light of the sensitive financial data that will be stored by the CAT. The exchanges highlighted the fact that they have been