ARTICLE
15 February 2022

CAT Offers "Roadmap" For CAIS Reporting Obligations For Small Firms

CW
Cadwalader, Wickersham & Taft LLP

Contributor

Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
CAT Customer and Account Information System.
United States Accounting and Audit
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The Consolidated Audit Trail ("CAT") provided a roadmap to assist "Small Industry Members" in meeting their Customer and Account Information System ("CAIS") reporting obligations. All Industry Members (Large and Small) must report Customer and Account information to CAT CAIS for all Active Accounts by July 11, 2022.

To comply, a broker-dealer must:

  • report equities, options and/or multi-leg transaction events containing the field firmDesignatedID to the CAT transaction system;
  • submit a CAT CAIS Registration Form;
  • grant CAT CAIS Test Environment Entitlement to personnel within the firm;
  • report CAT CAIS data through a CAT Reporting Agent or through self-reporting;
  • establish a CAT CAIS Reporting Relationship with a CAT Reporting Agent; and
  • certify for full CAIS production no later than June 20, 2022.

Primary Sources

  1. FINRA Small Firm Roadmap to July 11, 2022: CAT Customer and Account Information System (CAIS)

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