Small Firm CAT Set-Up and System Testing Reminder (4/24/20)

Okay, I waited until the initial FOCUS due date (4/23/20 with a potential extension to 5/7/20 if you need it) was past to send this reminder out to everyone regarding CAT.

SMALL FIRM CAT SET-UP AND SYSTEM TESTING REMINDER

Is your broker-dealer a firm that is a member of FINRA or a national securities exchange, and receives, originates and/or handles orders in “CAT Eligible Securities”, which includes NMS stocks and Listed Options, and/or OTC Equity Securities?

If the answer to this question is yes, then your firm has a Consolidated Audit Trail (CAT) reporting obligation and must register for and obtain access to CAT and prepare for reporting even if your firm plans to rely on a vendor or clearing firm to report equity and/or option transactions on its behalf.

There are no exemptions to CAT reporting, unlike OATS. If your firm handles even ONE order in NMS stocks and Listed Options and/or OTC Securities all of the steps on the following checklist apply.

Small Firm BD CAT Set-up and System Testing Completion Deadlines:

• Before April 20, 2020 – Small Industry Members currently reporting to OATS. One month extension provided by an SEC No Action letter! Now 5/20/20.

• Before December 2021 – Small Industry Members not currently reporting to OATS.

If you are unsure if any of the steps apply to your firm, please direct your questions to the FINRA CAT Helpdesk at 888-696-3348 or help@finracat.com.

Download the Checklist.

• CAT Onboarding Checklist (PDF - click here)

Download the SEC No Action Letter.

• SEC No Action Letter_CAT Extension (3/16/20 - click here)

Go to the CAT Webpage.

• www.catnmsplan.com (click here)

Stay strong. Stay safe. Stay in touch.

Paige

Paige W. Pierce

President

McLaughlin Ryder Investments, Inc.

(703) 684-9222, ext 215 w

(801) 949-5577 m

ppierce@mclaughlinryder.com