The US cash equities and options markets should not expect to start reporting trades to the consolidated audit trail until November 2019, noted officials from The Consolidated Audit Trail NMS during an industry conference call.

“The system will not be able to receive industry on the original November 2018 deadline,” according to Jack Wells, technical product manager at Cboe Global Markets. “The regulators are not expecting industry members to report such data until the system is ready to accept industry member reports.”

The organization and the CAT’s plan sponsor, Thesys CAT, submitted a revised master plan with new milestones to the US Securities and Exchange Commission on May 25, which the regulator has yet to approve.

Under the new master plan and with a recently elected four-person leadership team that will supervise the project going forward, the SRO body expects to complete the CAT rollout by November 2022.

Under the new master plan, industry members will have the option of submitting their equity trade reports in the CAT’s native format or an OATS-based format, which include firm-designated IDs and electronic linkages for straightforward one-to-one representative orders.

If industry members select the OATS-based option, Thesys CAT will convert their reports into the CAT’s native protocol. The OATS-based option would not be available for options-trade reporting.

However, the self-regulatory organizations and Thesys CAT envision retiring the OAT-based option eventually.

“We do not have a specific timeframe for that,” said Shelly Bohlin, a vice president at FINRA and member of the leadership team. “Once it gets to the point where it would be considered, there will be a cost-benefit analysis as well as a notice and comment period before the final decision is made.”

In the meantime, the organizations expect to publish the first draft of both equities-reporting protocols (Phase 2A) by August 1, which will be followed by a month comment period for the industry. The second draft and final specification should be available in October and by November 15, respectively.

The technical specifications for simple options (Phase 2B) will follow the same timeline even though the protocol will be implemented later, according to Bohlin. “Then you will see a similar contract for the timing of the initial drafts of the second on final drafts for Phase 2C and 2D.”