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CAT LLC Proposes Removal of all Personal Information on NMS

"FINRA appreciates the SEC's willingness to review and update the requirements for CAT. The Exemptive Order will substantially reduce the future PII footprint of CAT ... CAT LLC's proposal builds on the SEC's Exemptive Order and further reduces the risks and costs ... FINRA supports approval of CAT LLC's proposal."
Robert Cook, FINRA President and CEO
"FINRA appreciates the SEC's willingness to review and update the requirements for CAT. The Exemptive Order will substantially reduce the future PII footprint of CAT ... CAT LLC's proposal builds on the SEC's Exemptive Order and further reduces the risks and costs ... FINRA supports approval of CAT LLC's proposal."
Robert Cook, FINRA President and CEO

The Consolidated Audit Trail, LLC ("CAT LLC") filed a proposal with the SEC to amend the CAT Rules to make the removal of personal information mandatory.

As previously covered, the SEC issued no-action relief from the requirement to report certain personally identifiable information ("PII")—names, addresses and years of birth—to the Consolidated Audit Trail ("CAT").

CAT LLC's proposed amendment would: (i) require deletion of previously reported customer information; (ii) "prohibit the continued reporting of [previously] exempted Customer information to the CAT; (iii) "cover all natural persons (including, for example, foreign natural persons that are not reported with transformed SSNs or ITINs) and all legal entity Customers;" and (iv) "allow CAT LLC to achieve an estimated $12 million in annual cost savings." 

 

Primary Sources

  1. FINRA: News Blog: Eliminating all PII from CAT
  2. SEC: Proposal to Amend CAT: Joint Industry Plan; Notice of Filing of Amendment to the National Market System Plan Governing the Consolidated Audit Trail Regarding the Proposed Customer and Account Information System Amendment
  3. SEC: Order Granting Exemptive Relief, Pursuant to Section 36(a)(1) and Rule 608(e) of the Securities Exchange Act of 1934, from Certain Provisions of Section 6.4(d)(ii)(C) and Appendix D, Sections 9.1, 9.2 and 9.4 of the National Market System Plan

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Regulated Activities
Privacy Trade Reporting
Regulated Entities
Broker-Dealers
Body of Law
Securities Law
Jurisdiction
US - Federal
Organization
FINRA / MSRB / SEC Exchanges / SIPC / Accountants
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FINRA