Industry members and third-party trade-reporting providers who have an SRO membership and handle quotes or orders in NMS equities securities, OTC equities, or listed options have until June 27 to register as CAT reporters.

Firms that do not have an obligation to report to OATS have a responsibility to report to the CAT and will need to register, according to Paul McKenney, a senior director at FINRA.

“That would be true whether or not you are reporting on your own behalf or somebody else is going to be reporting data on your behalf,” he said during a recent industry conference call. “Either way, you will have to submit a registration form.”

The recently named plan processor has added a registration tab to the CAT NMS Plan’s homepage and started taking submissions on March 18.

“We already have a few dozen registration forms in,” said McKenney.

Amongst the information requested for registration includes: a registered principal, the manner of data submission (self-reporting or via a vendor), preferred reporting method (SFTP or via the CAT Reporting Portal), and the size of the firm (whether it has a capitalization of $500,000 or less).

CAT reporters also will need to include a CAT Reporting Industry Member ID number.

“It’s an identifier assigned by an SRO like FINRA or one of the exchanges a firm will use to report trades,” he noted. “An equivalent would be a maker participant identifier, trader mnemonic, or something along those lines.”

Although firms may have multiple identifiers, FINRA CAT is looking only for one that it would use as a default identifier in case a reporting issue arises.

The plan processor also spent a portion of the call setting out phases 2a’s and 2b’s testing and production timelines for equities and option respectively.

The testing environment for phase 2a will begin in December 2019 and will last until April 2020, when data submission will go into production.

“This will be focusing on file submission and data integrity,” said McKenney. “Those will be the only validation turned on at that point.”

Also in April 2020, FINRA CAT will open firm-linkage validation testing, for reports submitted from within firms that include information regarding new orders with routes. Industry members can test until July 2020, when reporting the reporting requirement goes live.

Subsequently, industry members will be able to test their inter-firm linkages starting in August 2020 until October 2020, when the validations go into production.

In September 2020, firms will be able to test their linkage validation to exchanges as well as FINRA’s Trade Reporting Facility until October 2020, when the environment goes into production.

Phase 2b’s timeline also begins testing in December 2020 but will last until May 2020 while firm-linkage, inter-firm linkage, and exchange/TRF linkage validations will go live in August 2020, October 2020, and December 2020 respectively.

McKenney ended his presentation noting that the CAT NMS Help Desk is up, functional, and waiting to answer any industry questions.