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ARTICLE · 02 JULY 2020

FINRA Proposes Amendments To CAT Reporting Requirements

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FINRA requested that the SEC waive the 30-day post-filing date waiting requirement so that the proposed amendments would be effective on June 22, 2020.

United StatesFinance and Banking
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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FINRA proposed amendments to the FINRA Consolidated Audit Trail ("CAT") Rules ("Rule 6800 Series") to (i) add consistency for certain NMS Plan exemptions and (ii) "facilitate the retirement of current reporting systems."

According to FINRA, the proposed amendments would, among other things:

  • add to the CAT further data elements to advance the "retirement" of the Order Audit Trail System ("OATS");
  • add to the CAT-reporting requirements further data elements related to OTC Equity Securities, which FINRA currently receives from alternative trading systems engaging in OTC Equity Securities trades for the purposes of regulatory oversight;
  • require time reporting to the Central Repository in increments as small as nanoseconds; and

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