The SEC issued Orders granting exemptive relief (see here and here) to support the implementation of the
Consolidated Audit Trail ("CAT").
In the first Order, the SEC pushed back certain CAT
implementation deadlines for equities and options reporting in
light of the COVID-19 pandemic. In the second Order, the SEC
permitted certain introducing brokers with less than $500,000 in
total capital (i.e., those brokers that meet the
net capital requirements for small broker-dealers under
Rule 0-10(c)(1) of the Securities Exchange Act of 1934) to be
treated as small broker-dealers for purposes of the CAT.
The SEC set the following CAT reporting dates:
- June 22, 2020: Initial phase-in of equities reporting for large
broker-dealers and small broker-dealers reporting to FINRA's
Order Audit Trail System;
