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CAT Small Firm Onboarding Checklist

Is your firm a broker-dealer that is a member of FINRA or a national securities exchange, and receives, originates and/or handles orders in “CAT Eligible Securities”, which includes NMS stocks and Listed Options, and/or OTC Equity Securities? 

If the answer to this question is yes, then your firm has a Consolidated Audit Trail (CAT) reporting obligation and must register for and obtain access to CAT and prepare for reporting even if your firm plans to rely on a vendor or clearing firm to report equity and/or option transactions on its behalf. There are no exemptions to CAT reporting, unlike OATS. If your firm handles even ONE order in NMS stocks and Listed Options and/or OTC Securities all of the steps on the following checklist apply. 


  • Full CAIS Production Certification and Compliance Deadlines Extended
    The Participants have determined to delay the full Customer Account Information System (“CAIS”) compliance deadline from July 11, 2022, to a date projected to be in Q4 2022. For additional information, see Full CAIS Production Certification and Compliance Deadlines Extended.

Broker-Dealers – Small Firm CAT Set-up and System Testing Completion Deadlines 

  • Before April 20, 2020 – Small Industry Members currently reporting to OATS. 
  • Before December 2021 – Small Industry Members not currently reporting to OATS. 

If you are unsure if any of the steps apply to your firm, please direct your questions to the FINRA CAT Helpdesk at 888-696-3348 or [email protected]. For more detailed information, please refer to the FINRA CAT Industry Member Onboarding Guide

Download the Checklist.