Representative Orders
CAT covers all street-side orders – including all proprietary orders for non-FINRA members.
| OATS | CAT |
| Only applicable to FINRA members | Applies to every U.S. registered broker-dealer |
| Does not capture proprietary orders | Clearly deciphers proprietary vs. representative (customerdriven) orders |
| Requires multiple requests to track down representative orders | FDID/CCID links avoid the need for multiple requests to research activity |
Reportable Data & Events
New reportable data and event types will expose resource principal, order activity or aggregated average price order attributes.
| OATS | CAT |
| No need to report market making with street-side vs. principal | Eliminates market making exclusions |
| Recording of electronic quotes are limited in scope | Includes OTC equities quoting activity and electronic quotes (exchanges and NMS) |
| Requires only one timestamp on manual events | Requires capture and report of two timestamps on manual events |
Accuracy of Reporting
Firms must have a clear understanding of what they are reporting when the move from OATS to CAT occurs – which may require different approaches.
| OATS | CAT |
| Very high compliance rate of more than 99% | Will use FINRA’s surveillance patterns from OATS data |
| High accuracy relied on heavily for FINRA surveillance | Accuracy will rely on achieving the same high compliance rates as OATS |
| Useful for comparing and contrasting with CAT data and surveillance results | Conducting early and frequent testing will drive accurate reporting |
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