As reporting to the SEC Consolidated Audit Trail (CAT) fast approaches, with large industry participants and small industry participants reporting to the Order Audit Trail System (OATS) due to submit files on April 20, 2020, vendors are finalising solutions to support firms subject to the regulation.
Among them is S3, a provider of regulatory reporting technology – including a specialism in SEC rules 605 and 606 covering disclosure of order execution and order routing information, trade surveillance, and post-trade analytics. The company has built on its reporting experience to offer a managed service solution for the CAT and is initially working with a major exchange (that it cannot currently name) to provide a service for its hosted brokers. It is also working with its own broker clients and talking to others about provision of the CAT service, which validates exchange files, submits required data to the CAT, and handles any data problems with individual brokers.
Mark Davies, CEO at S3, says the company’s CAT solution is a natural extension of its reporting capabilities, which already handle a substantial volume of data. The company has been working with the exchange’s brokers and FINRA for a few months to get data flowing and is ready for first submissions in April. Davies adds: “With new regulations coming down the pipeline, firms must be prepared to make adjustments that are often costly. S3’s CAT reporting service intends to mitigate that expense and lift much of the compliance burden off our clients.”
S3 prides itself on offering an integrated solution across SEC 605 and 606, transaction cost analysis (TCA), market surveillance, best execution and now the CAT. While its sales focus is only on the US at the moment, it could move into European markets on the strength of its expertise around SEC 605 and 606, rules that are similar to the RTS 27 and 28 reporting standards under Europe’s Markets in Financial Instruments Directive II (MiFID II).
Coming back to the CAT, Davies notes ongoing industry issues around data privacy, which without an acceptable solution, are likely to escalate ahead of the July 2022 deadline for reporting of customer and account information to the CAT.