The New CAT Timeline
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Across the industry, firms find themselves in varied states of readiness to comply with the Consolidated Audit Trail (CAT) in time for the rollout. Along with the known challenges of CAT preparation and implementation, there are many opportunities for firms to capitalize on data consolidation and transparency while transforming their compliance and operations models to drive strategic business initiatives.
Four main approaches are now emerging across the CAT readiness lifecycle, each with its own unique set of critical decisions to make around goals and objectives in relation to current-state circumstances, and important questions to ask about vendors, data and workflows. These two aspects of CAT readiness then converge into a specific timeline that firms must follow to be truly ready for industry testing in Q4 2019.
1. Just starting.
A firm’s CAT implementation timeline greatly depends on the complexity of its existing system architecture. Firms who are just starting to evaluate their options for CAT reporting must first take a close look at their current-state model, analyze specific business requirements, and assess potential vendors and solutions.
Top questions to ask:
Top Questions to Ask:
2. Working with existing vendor.
Firms who currently use vendors for their transaction processing and OATS (Order Audit Trail System) reporting must evaluate existing or planned capabilities for CAT reporting, rules, workflows
Top questions to ask:
Top Questions to Ask:
3. Operations transformation.
Firms at this level of readiness use a process-driven approach to CAT which includes team consolidations, workflow models, and perhaps process model re-engineering to determine new approaches to implementation and data aggregation. A data lake may be a result, but is usually not the logical starting point of the initiative, since compliance is the main focus initially then later included the operations part of the business.
Top questions to ask:
Top Questions to Ask:
4. Front-office data lake.
Firms taking a strategic, data-centric approach in the context of front-office data are consolidating data not only for the CAT
Top questions to ask:
Top Questions to Ask:
Regardless of the
Beyond the perils of missing the deadline for CAT reporting, there are other risks inherent in choosing the wrong approach or solution set. A firm’s chosen solution architecture will need to accommodate ongoing compliance and business change with minimal refactoring. Otherwise, a firm’s CAT reporting solution will face the same fate as many of the G20-based Non-Financial Regulatory Reporting (NFRR) rollouts – solution replacement within months of go-live. Inevitable changes in scope and other details of CAT reporting means that solution architectures must be flexible enough to adapt.
The right approach to CAT readiness can help firms improve data management from the front to the back offices, create a more efficient regulatory reporting operation that handles regulatory requests and queries faster and with greater ease, and ultimately drive strategic business initiatives that unlock new revenue streams and competitive advantages.