The Interim Reporting Obligation Schedule set forth in CAT Alert 2022-01 is being updated as follows:
Interim Obligation 1 – No change
Interim Obligation 2 – No change
Interim Obligation 3 – No change
Interim Obligation 4 – Moved from December 5, 2022 to March 10, 2023
Full Compliance Go-Live – Moved from December 12, 2022 to March 17, 2023
In addition:
The 2022 User Accounts Entitlement Certification Period for CAT Reporting Agents (not applicable to Industry Members) is September 12, 2022 – November 14, 2022. During this period, a Certification Representative (CRep) for each organization must certify that accounts with access to CAT applications, data and tools are valid and users are entitled only to the entitlements (privileges) necessary to perform their current job responsibilities.
The Participants have determined to delay the full Customer Account Information System (“CAIS”) compliance deadline from July 11, 2022, to December 12, 2022. This extension of the compliance deadline will assist in addressing reporting challenges and delays in error feedback and processing, and will allow time for such issues to be remediated. The CAIS testing environment has been available since January 31, 2022, and the production environment has been available since April 25, 2022.
Please see the attachment to view the Consolidated Audit Trail, LLC's 2022 Financial and Operating Budget.
As previously communicated, Industry Members must complete an annual certification for Business Clock Synchronization by March 15th of each year.
This announcement affects all Industry Members testing in the Test Environment on October 20, 2021 and October 21, 2021.
Cboe’s C1 Option Exchange is introducing Global Trading Hours, where trading cycles will span multiple calendar days and trading can occur on non-trading days, such as Sundays and US holidays. FINRA CAT is making changes to our processing to ensure proper assignment of trade date and linkage across trading cycles.
The 2021 Entitlement Certification Period for CAT Reporting Agents (Not Applicable to Industry Members) is scheduled for September 13, 2021 – November 15, 2021. During this period, each organization is required to review and verify all CAT accounts (user, administrator, machine).
FINRA CAT requests Industry Member feedback in support of the Plan Processor’s annual review of the Business Clock requirements for the Consolidated Audit Trail. FINRA CAT has prepared a survey of 32 questions for Industry Members to complete regarding their current clock synchronization standards and practices, based on the type of CAT Reporter, type of Industry Member and type of system.