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MENOs and MEORs and MEOFs, Oh My! – A High-Level Overview of CAT Reporting

The Consolidated Audit Trail (CAT) is the biggest change – and many would offer, challenge – to regulatory reporting in the broker-dealer industry in some time.  Perhaps ever.  Accurate reporting requires a blend of regulatory expertise and technical skill to successfully translate the sequence of actions in a securities transaction into the events that need to be reported to the CAT.  MENOs and MEORs and MEOFs, indeed.

All industry members, including entities registered as a broker-dealer and a registered investment adviser, must report to the CAT.1 Although an industry member can use a reporting agent to help it discharge this obligation, at the end of the day, it remains responsible for ensuring that it reports complete and accurate information.  FINRA regularly updates several resources to help industry members meet this requirement.  The Industry Member Reporting Scenarios documents help industry members understand what transaction and customer account information they need to report to the CAT and to the Customer and Account Information System (CAIS), respectively.  The Technical Specifications documents guide industry members on how to report this information.  FINRA also posts various FAQs and hosts regular informational calls to supplement these resources.

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Thank you for reading this article.  Please know that I wrote it for informational purposes only (some may consider it ADVERTISING MATERIAL) and did not intend for it to be legal advice or to form an attorney-client relationship with you – especially in jurisdictions where I am not licensed to practice law.  I encourage you to seek your own counsel to help you with your specific situation.  To that end, I invite you to contact me if you would like to discuss my services.

I enable broker-dealers, registered investment advisers and their associates to spend more time growing their business by helping them address a wide range of legal and compliance responsibilities with clear and detailed advice.