PUBLIC COMMENT PERIOD – Extensions for CAT Proposal

This gap analysis proposal seeks to address requirements identified by Consolidated Audit Trail (the “CAT”) Working Group related to data reporting required by the CAT NMS Plan.

CAT NMS is a national market system plan submitted by national securities exchanges and national securities associations to create, implement, and maintain a consolidated audit trail (the “CAT”) that would allow regulators to more efficiently and accurately track all activity in U.S. equity and listed options markets. The SEC approved the CAT NMS Plan on November 15, 2016.

In accordance with SEC Rule 613, the CAT NMS Plan requires a Central Repository that will comprehensively track orders throughout their lifecycle and identify the Participants (FINRA and national securities exchanges) and Industry Members (Broker-dealers) handling them, as well as the account holders and authorized traders for any account that originates an order (Customers). Specific data elements will be submitted by Participants, Industry Members, and CAT Reporting Agents (Third party firms reporting on behalf of other entities).

The following document is used as a reference and input to this gap analysis document:

Please post feedback, comments, and questions as replies to this discussion thread.

A link to the proposal can be found at:

The public comment period ends on November 12, 2019.