SEC Chair Highlights Successful Implementation of CAT

SEC Chair Jay Clayton attributed the successful implementation of the Consolidated Audit Trail ("CAT") to specific implementation details and milestones, engagement with stakeholders and focused leadership.

In a public statement, Mr. Clayton explained that the purpose of CAT - to "facilitate cross-market oversight and analysis" - has been clear for many years, but its implementation, beginning with its restructuring in 2017 (see previous coverage), was challenging. He said, that progress only picked up after certain process improvements: (i) the selection of FINRA as processor by self-regulatory organizations, (ii) the SEC's exemptive order to phase in broker-dealer reporting (see previous coverage), and (iii) the SEC's financial accountability amendment establishing key milestones with a specific focus on CAT reporting (see previous coverage).

Additionally, Mr. Clayton highlighted stakeholders' engagement through quarterly progress reports and extensive industry feedback, public engagement through comments, and focused leadership as contributing to CAT's success.