Effective September 1, 2021, FINRA is amending its rulebook to eliminate the Order Audit Trail System (OATS) rules in the FINRA Rule 7400 Series and FINRA Rule 4554 (Alternative Trading Systems — Recording Reporting Requirements and of Order and Execution Information for NMS Stocks) (collectively referred to as the “OATS Rules”). FINRA has determined that the accuracy and reliability of the Consolidated Audit Trail (CAT) meet the standards approved by the SEC and has determined to retire OATS as of September 1, 2021.
Key Points
- The OATS Rules will be deleted from the FINRA rulebook effective September 1, 2021.
- firms are still required to report to OATS all order events that take place on or prior to August 31, 2021.
- OATS will accept reports through September 16, 2021 for order events that take place on or prior to August 31, 2021.
Regulatory Notice 21-21
In Regulatory Notice 21-21, FINRA states that the OATS Rules will be deleted from the FINRA rulebook effective September 1, 2021 and replaced with the new Consolidated Audit Trail (CAT) for trade reporting.
Firms must continue to report to OATS all order events that occur on or before August 31, 2021. Reports submitted to OATS for order events that occur after August 31, 2021, will be rejected. In other words, August 31, 2021, will be the last “OATS Business Day,” as defined under Rule 7450(b)(3), for which OATS will accept order events and perform routine processing (including incorporation of corrections and repairs of rejections).
OATS will continue to accept reports for order events that occur on or before August 31, 2021, (including, but not limited to, late and corrected reports for such order events) through September 16, 2021. Firms must ensure that their OATS reporting is accurate and complete for all order events that occur on or before August 31, 2021. To assist firms in meeting their reporting obligations, existing OATS guidance will remain posted and available on FINRA’s website for a period of time following OATS retirement.
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