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Recent CAT Developments: Here’s What’s New After 11 Years

Article from TabbForum: 


While the SEC first approved the Consolidated Audit Trail (CAT) in 2012, writes Howard Meyerson, Managing Director of the Financial Information Forum, there have been a series of important recent developments relating to CAT that firms should be aware of. In this CAT update, Mr. Meyerson highlights a number of these developments that will impact firm trading, technology, operations, compliance and finance.

The SEC first approved CAT in 2012, but due to important ongoing developments CAT is still a significant focus for many industry members. Industry members should be aware of the following significant recent developments relating to CAT.

CAT Reporting for Certain Verbal Activity

In 2020 the SEC issued an exemption from reporting certain verbal activity to CAT. This exemption applies where a dealer verbally communicates a price to a customer, either on or off an exchange floor, but the dealer is required to subsequently receive an order from the customer (or generate an order based on the customer’s assent) before a trade can occur. This exemption was set to expire on July 31, 2023. Expiration of the exemption would have caused a major disruption to floor and upstairs trading activity. On July 31, 2023 the SEC extended this exemption for an additional three years, until July 31, 2026.

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