Consolidated Audit Trail

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(Also see the entry for Consolidated Audit Trail on MarketsReformWiki here:

The Securities and Exchange Commission ordered the creation of the Consolidated Audit Trail (CAT) in 2012 after regulators found they didn’t have enough information to explain the “Flash Crash” that occurred in May 2010. It is designed to compile detailed information on orders and trades for the US equity and options markets. One SEC commissioner, Kara Stein, said the database could become the “Hubble telescope of securities markets.” [1]

SEC Rule 613 required FINRA and the U.S. securities exchanges to jointly submit a National Market System (NMS) plan detailing how they would develop, implement and maintain a consolidated audit trail that would track orders throughout their life cycle and identify the broker-dealers handling them, thus allowing regulators to more efficiently track activity in Eligible Securities throughout the U.S. markets.

The Consolidated Audit Trail (CAT) is designed to collect and accurately identify every order, cancellation, modification and trade execution for all exchange-listed equities and options across all U.S. markets.

CAT Delays

Implementation of the CAT was delayed for several years. Phase I was finally launched on November 15, 2018, although some "bugs" still remained to be ironed out. On day one of the first phase, only the US exchanges, including Nasdaq, the New York Stock Exchange and Cboe Global Markets, began reporting market information. That came after a one-year delay on the original timetable of milestones for the scheme amid calls by exchanges for the postponement. FINRA had been working with the exchanges to develop an NMS plan that met the requirements of Rule 613.[2]

Thesys Group was the company hired to build the database. But the Phase I launch in November of 2018, was one year late and without the functionality that was expected. The exchanges overseeing the contract said in January 2019 they would switch to a new vendor. The group said Thesys “is providing necessary services through the transition period,” the Wall Street Journal reported.[3]

The exchanges are evaluating how the switch will affect coming deadlines, including "Phase II," scheduled to begin in November 2019, which calls for the large brokerage firms to report orders to the data warehouse.[4][5]

Just days before the Thesys news, the SEC announced it had hired Manisha Kimmel to coordinate its oversight of the project. Kimmel is an expert in trading technology who previously led a consortium of Wall Street banks and broker-dealers that implement complex technology solutions.[6]

In September 2019, with the CAT still not fully launched, SEC Chairman Jay Clayton threatened to levy financial penalties if the industry missed further deadlines. Large brokers are due to begin reporting to the database on April 30, 2020. Clayton said that if members of the consortium missed that deadline, they would lose 25% of the fees they are entitled to for running the system. Each delay in 90-day segments would result in another 25% reduction.[7]


  1. Stock-Market Supercomputer to Launch With Glitches. The Wall Street Journal.
  2. Consolidated Audit Trail. FINRA.
  3. Stock Exchanges to Fire Company Building Stock-Market Supercomputer. The Wall Street Journal.
  4. Stock Exchanges to Fire Company Building Stock-Market Supercomputer. The Wall Street Journal.
  5. US stock market surveillance system goes live. The Financial Times.
  6. Stock Exchanges to Fire Company Building Stock-Market Supercomputer. The Wall Street Journal.
  7. SEC Pressures Exchanges on Long-Delayed Market-Surveillance Project. The Wall Street Journal.