CAT Consulting Services

CAT CONSULTING SERVICES

Implementing and verifying CAT compliance.

Consolidated Audit Trail (CAT)

CAT’s goal of improving trading surveillance has introduced significant reporting complexity to securities brokers. CAT has extended previous regulatory requirements by including new events and business activities, widening product scope, and implementing a strict error-correction cycle. Most critically, its broad surveillance capabilities include using personally identifiable information (PII) for each transaction, trying together the “what” with the “who” for the first time in reporting history.

The complexity of CAT requires a necessary combination of regulatory, institutional, security, and data-strategy expertise. With our deep business domain knowledge and technical skill, we prepare firms for CAT compliance while ensuring the most secure and efficient life cycle for their data.

Our services include Regulatory Health Checks that can assess your current state of compliance as well as a range of targeted services for each stage of CAT compliance.

Regulatory Health Checks

Our comprehensive reviews of your applications, infrastructure, and business processes can provide your firm with a roadmap to CAT compliance. These Regulatory Health Checks focus on data quality, completeness, and accuracy, providing:

Recommendations for reconciling gaps between CAT and the order audit trail system (OATS) it supersedes

Advice on avoiding re-occurrences of reporting breaks

Remediation plans for incomplete, erroneous, and inaccurate data

We offer our Regulatory Health Checks in three standard tiers, with an option to tailor a custom Health Check upon request.

Silver

Rule Interpretation
In-House Business Requirements
Completeness

Gold

Rule Interpretation
In-House Business Requirements
Completeness

All of the above, plus:

Testing
Data Quality
Data Source
Event Eligibility

Platinum

Rule Interpretation
In-House Business Requirements
Completeness

Testing
Data Quality
Data Source
Event Eligibility

All of the above, plus:

Product Eligibility
Report Generation
Customer Reference Data
Error Correction
Surveillance

Targeted CAT Offerings

Gap Analysis

OATS-to-CAT comparison to identify gaps, maximize efficiencies, and get ahead of potential challenging uplifts

Health Check and Rule Interpretation

Detailed analysis of your firm’s path to compliance, with interpretation of CAT rules uniquely addressed to your needs

Front-to-Back Analysis

Full assessment of the applications, infrastructure, and processes that make up your business value chain

Eligibility

Defined scope for relevant products, including product eligibility (e.g. cash equity/options), event eligibility (e.g. new order vs. order accept), and electronic/manual, to ensure accurate reporting

End-to-End Implementations

Full suite of services to achieve successful implementation and ongoing support: establishing workstreams, documenting business and technical requirements, developing to meet specs, testing, and launching with appropriate controls

Testing

Comprehensive testing of in-house implementation, including development of applicable use cases to ensure completeness and accuracy

Technical Requirements

Review and articulation of business requirements, data sourcing, business decision models, business process maps, user stories, and acceptance criteria to ensure changes are both manageable and auditable

Enhanced Surveillance

Design surveillance capabilities given new broader data points and adherence

Data Strategy and Storage

Guidance on overall data strategy, retention, and sustained usability, including appropriate data masking technology to protect client’s Pll

Data Mapping

Data-lake contact, data sourcing, and transparency between OMS and CAT reporting

Controls

Scope of controls impacting accuracy, timeliness, and runtime controls

Client Reference Data

Solutions for Firm Designated ID (FDID) and for protecting other client Pll

Report Generation

Report delivery per product/event and data transformation to CAT-native format Dashboard and Data Visualization

Dashboard and Data Visualization

Practical, user-friendly interfaces to optimize on throughput and highlight pain points

Error Corrections

Requirements and processes to meet compliance for error-correction cycle, which must be submitted within 1.5 days

BAU Transition

Procedures, escalation process, training materials, etc. to allow your firm to seamlessly incorporate new CAT solutions into existing established business operations