Each Industry Member is responsible for complying with applicable CAT requirements, including those related to recordkeeping and record retention, set forth in the CAT Compliance Rules. Outsourcing a function to a vendor or other third party does not relieve the Industry Member of its ultimate responsibility for compliance with the CAT Compliance Rules or other applicable securities laws, rules or regulations (e.g., SEC Rule 17a-4). To the extent that an Industry Member seeks to rely on its third party CAT Reporting Agent to maintain and preserve records on its behalf, the Industry Member must take steps reasonably designed to ensure that its CAT Reporting Agent is capable of performing these functions consistent with the CAT Compliance Rules and other applicable securities laws, rules or regulations.
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If a firm uses a third party CAT Reporting Agent to submit data on its behalf, can the firm satisfy its CAT recordkeeping obligations by having the third party retain the data and provide it upon request?
If a firm uses a third party CAT Reporting Agent to submit data on its behalf, can the firm satisfy its CAT recordkeeping obligations by having the third party retain the data and provide it upon request?