FINRA proposed updating its Manual to reflect the new FINRA subsidiary, FINRA CAT LLC, an entity designed to further FINRA's compliance "with respect to the creation, operation and maintenance of a central [customer and order data] repository." The new entity is intended to be a dedicated resource solely for carrying out FINRA's obligations as Plan Processor of the consolidated audit trail ("CAT").

The update will take account of the governance procedures for the new subsidiary.

In particular, the proposal would:

  • codify the delegation of certain responsibilities and functions to FINRA CAT, LLC under the "Plan of Allocation and Delegation of Functions by FINRA";
  • make conforming amendments to the Delegation Plan to provide for FINRA CAT, LLC; and
  • make conforming amendments to the By-Laws of FINRA Regulation, Inc. and to the FINRA Rules.

FINRA filed the proposal for immediate effectiveness.

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