# How Does the CAT System Technically Differ from the Previous OATS Framework? ▴ Question

**Published:** 2025-08-04
**Categories:** Question

---

![A sleek blue and white mechanism with a focused lens symbolizes Pre-Trade Analytics for Digital Asset Derivatives. A glowing turquoise sphere represents a Block Trade within a Liquidity Pool, demonstrating High-Fidelity Execution via RFQ protocol for Price Discovery in Dark Pool Market Microstructure](https://options.greeks.live/wp-content/uploads/2025/07/advanced-institutional-digital-asset-derivatives-rfq-execution-system-for-optimal-price-discovery-and-high-fidelity-execution.jpg)

![A central teal sphere, representing the Principal's Prime RFQ, anchors radiating grey and teal blades, signifying diverse liquidity pools and high-fidelity execution paths for digital asset derivatives. Transparent overlays suggest pre-trade analytics and volatility surface dynamics](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-and-market-microstructure.jpg)

## Concept

The transition from the [Order Audit Trail System](https://prime.greeks.live/area/order-audit-trail-system/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (OATS) to the [Consolidated Audit Trail](https://prime.greeks.live/area/consolidated-audit-trail/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (CAT) represents a fundamental re-architecting of market surveillance infrastructure. This shift is an evolution from a jurisdictionally-limited, post-trade reporting mechanism to a comprehensive, full-lifecycle data repository for all U.S. equity and options markets. The core technical divergence arises from the mandate given to each system. OATS was designed by a Self-Regulatory Organization (SRO), FINRA, to oversee its member firms’ activities in specific securities.

CAT, conversely, was mandated by the [Securities and Exchange Commission](https://prime.greeks.live/area/securities-and-exchange-commission/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (SEC) under Rule 613 to provide regulators with a single, consolidated view of all trading activity across all national market system (NMS) securities, including equities and options, from the moment of order inception through to routing, cancellation, modification, and execution. This foundational difference in mandate dictates every subsequent technical variation between the two frameworks.

OATS functioned as a series of snapshots, capturing specific events in the life of an order as reported by [FINRA members](https://prime.greeks.live/question/how-does-the-ccp-default-waterfall-protect-non-defaulting-members/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). Its technical scope was confined, focusing on data relevant to FINRA’s surveillance patterns. The system required firms to report events like new orders, routes, and executions, but the linkage of these events into a coherent lifecycle often required significant effort by regulators, sometimes involving multiple requests to [different firms](https://prime.greeks.live/question/how-do-firms-typically-manage-the-synchronization-of-timestamps-across-different-trading-systems-for-cat-reporting/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) to piece together a complete audit trail.

The data was sufficient for its time, yet the increasing fragmentation and speed of modern electronic markets rendered this approach insufficient for cross-market analysis. The system did not, for example, have a native mechanism for tracking an order that moved between different broker-dealers or across multiple exchanges with the same level of granular, unified identity.

> The CAT system was engineered to provide a seamless, end-to-end view of all order events across the entire U.S. market, a capability OATS was not designed to deliver.

CAT’s architecture addresses these limitations directly. It is built around the concept of a unique, persistent order identifier that tracks a client’s directive from its origination. This is accomplished through a system of Firm Designated IDs (FDIDs) which are linked to customer-level identifiers within a separate, highly secure repository. This design provides regulators with the ability to trace the complete journey of an order, from the initial customer instruction to the final execution, regardless of how many different firms or venues handle it along the way.

The technical requirement extends beyond [FINRA](https://prime.greeks.live/area/finra/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) members to encompass every registered broker-dealer in the United States, creating a dataset of unparalleled breadth and depth. The inclusion of all proprietary trading and quoting activity from exchanges and OTC market makers further expands this data universe, providing a complete picture of market dynamics that was previously unattainable.

![A transparent, precisely engineered optical array rests upon a reflective dark surface, symbolizing high-fidelity execution within a Prime RFQ. Beige conduits represent latency-optimized data pipelines facilitating RFQ protocols for digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-system-architecture.jpg)

## What Is the Core Architectural Distinction

The primary architectural divergence lies in the data model and its scope. OATS operated on a firm-centric data model where each FINRA member reported its slice of an order’s life. CAT implements a market-centric data model where all participants contribute data to a single, unified [audit trail](https://prime.greeks.live/area/audit-trail/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). This is the difference between assembling a puzzle from disparate pieces and having a complete blueprint from the start.

OATS required regulators to be archeologists, reconstructing events after the fact. CAT empowers them to be architects, with a clear view of the entire structure as it is being built.

This is reflected in the reporting requirements. OATS had nine distinct report types, such as New Order, Route, and Execution reports. CAT collapses these into a series of more granular ‘event’ reports that capture a wider array of activities with greater precision. For instance, CAT requires two timestamps for manual order events ▴ one for when the order was received and another for when it was electronically captured ▴ whereas OATS only required one.

This seemingly minor detail provides critical insight into potential delays or inconsistencies in order handling, a level of granularity that defines the CAT framework’s entire philosophy. The system is designed to leave no ambiguity in the lifecycle of an order.

![A dark blue, precision-engineered blade-like instrument, representing a digital asset derivative or multi-leg spread, rests on a light foundational block, symbolizing a private quotation or block trade. This structure intersects robust teal market infrastructure rails, indicating RFQ protocol execution within a Prime RFQ for high-fidelity execution and liquidity aggregation in institutional trading](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-framework-multi-leg-spreads-best-execution-capital-efficiency.jpg)

![Precision metallic bars intersect above a dark circuit board, symbolizing RFQ protocols driving high-fidelity execution within market microstructure. This represents atomic settlement for institutional digital asset derivatives, enabling price discovery and capital efficiency](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-protocol-execution-precision-systemic-framework.jpg)

## Strategy

The strategic impetus behind the replacement of OATS with CAT was the need for a surveillance system that could effectively monitor a modern, high-speed, and fragmented market. The “Flash Crash” of 2010 starkly revealed the inability of the existing fragmented audit trail systems, including OATS, to provide regulators with a timely and complete picture of market-wide events. The strategy, therefore, was to construct a single, authoritative data source that would allow for the comprehensive reconstruction of all market activity. This required a strategic shift in four key areas ▴ reporting scope, data granularity, customer identification, and lifecycle linkage.

The expansion of the reporting scope is the most visible strategic change. OATS was limited to FINRA members and primarily covered equities traded on Nasdaq and the OTC markets. CAT’s scope is universal, covering all NMS stocks and listed options, and applying to every U.S. registered broker-dealer.

This strategic decision eliminates the regulatory blind spots that existed when an order moved from a FINRA member to a non-member or was routed to an exchange outside of FINRA’s direct oversight. By mandating that all broker-dealers report to a single, centralized system, the SEC created a level playing field for surveillance and ensured that no part of an order’s journey could disappear into a regulatory gap.

![A sophisticated metallic and teal mechanism, symbolizing an institutional-grade Prime RFQ for digital asset derivatives. Its precise alignment suggests high-fidelity execution, optimal price discovery via aggregated RFQ protocols, and robust market microstructure for multi-leg spreads](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-engine-precision-execution.jpg)

## How Does Data Granularity Impact Regulatory Capability

The second strategic pillar is the immense increase in data granularity. OATS collected what was necessary for its surveillance programs, but CAT was designed to collect a much richer dataset to enable more sophisticated, cross-market analysis. This includes the capture of quoting information from OTC market makers and exchanges, which was not a part of the OATS framework.

This data provides regulators with insight into market maker behavior and liquidity provision, which are critical components of market stability. The requirement to report additional event types and data elements, including more detailed timestamps and information about how orders are handled internally at a firm, provides a high-fidelity recording of market activity.

The table below outlines some of the key strategic differences in data reporting between the two systems, illustrating the leap in scope and detail.

| Reporting Aspect | OATS Framework | CAT System |
| --- | --- | --- |
| Reporting Entities | FINRA Member Firms | All U.S. Registered Broker-Dealers |
| Covered Securities | Nasdaq and OTC Equities | All NMS Equities and Listed Options |
| Proprietary Orders | Limited capture; primarily focused on customer orders | Comprehensive capture of all proprietary and customer orders |
| Quoting Activity | Not generally required | Required for OTC market makers and exchanges |
| Manual Event Timestamps | Single timestamp required | Dual timestamps required (receipt and capture) |
| Customer Identification | Indirect and often requires multi-firm inquiries | Standardized through a system of FDIDs linked to a central customer database |

![Close-up reveals robust metallic components of an institutional-grade execution management system. Precision-engineered surfaces and central pivot signify high-fidelity execution for digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/institutional-grade-digital-asset-derivatives-rfq-execution-precision-optimizing-market-microstructure-for-best-execution-and-prime-os.jpg)

## The Strategic Importance of Lifecycle Linkage

Perhaps the most profound strategic shift is in the approach to lifecycle linkage. OATS provided the data points, but connecting them, especially across different firms, was a manual and time-consuming process for regulators. CAT was strategically designed to automate this linkage. The CAT NMS Plan establishes the concept of a “[Firm Designated ID](https://prime.greeks.live/area/firm-designated-id/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite)” (FDID), a unique identifier assigned by a broker-dealer to each of its customers.

While the customer’s personal information is stored in a separate, secure database accessible only under strict conditions, the FDID is attached to every order event reported to CAT. This allows the system to automatically link all activity from a single source, even if the orders are routed through multiple brokers or executed on different venues. This creates a complete, unambiguous audit trail for every market participant, a strategic capability that fundamentally enhances the ability of regulators to detect manipulative behavior and understand complex trading patterns.

![A meticulously engineered mechanism showcases a blue and grey striped block, representing a structured digital asset derivative, precisely engaged by a metallic tool. This setup illustrates high-fidelity execution within a controlled RFQ environment, optimizing block trade settlement and managing counterparty risk through robust market microstructure](https://options.greeks.live/wp-content/uploads/2025/08/precision-engineered-institutional-digital-asset-derivatives-rfq-execution.jpg)

![A transparent glass sphere rests precisely on a metallic rod, connecting a grey structural element and a dark teal engineered module with a clear lens. This symbolizes atomic settlement of digital asset derivatives via private quotation within a Prime RFQ, showcasing high-fidelity execution and capital efficiency for RFQ protocols and liquidity aggregation](https://options.greeks.live/wp-content/uploads/2025/07/architecting-high-fidelity-execution-for-institutional-digital-asset-derivatives-rfq-protocols-and-systemic-liquidity-aggregation.jpg)

## Execution

The execution of reporting under the CAT framework is a far more complex and demanding undertaking than it was for OATS. The transition requires significant changes to a firm’s internal systems, data management practices, and compliance workflows. While OATS reporting was a mature and well-understood process for FINRA members, CAT introduces new data elements, stricter synchronization standards, and a more unforgiving error correction process. The execution phase is defined by the need to capture, timestamp, and report a wider array of data with a higher degree of precision across a broader range of securities and order types.

A central challenge in the execution of [CAT reporting](https://prime.greeks.live/area/cat-reporting/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) is the management of customer and account information. The requirement to assign and use Firm Designated IDs (FDIDs) means that firms must have robust systems for mapping all order activity to the correct customer identifier. This process, managed through the Customer and Account Information System (CAIS), necessitates a level of data governance that was not required for OATS.

Firms must be able to accurately report customer attributes and ensure that the FDID used on order reports correctly links to the corresponding customer record in CAIS. Any discrepancy can lead to reporting errors and regulatory scrutiny.

> The move from OATS to CAT necessitates a complete overhaul of a firm’s data capture and reporting infrastructure to meet the new standards of granularity and linkage.

![Precision-engineered metallic tracks house a textured block with a central threaded aperture. This visualizes a core RFQ execution component within an institutional market microstructure, enabling private quotation for digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-rfq-execution-framework-precision-microstructure-component.jpg)

## What Are the Practical Reporting Workflow Changes

The day-to-day reporting workflow under CAT is substantially different from OATS. The nine OATS report types are replaced by a more flexible, event-based system in CAT. Firms must capture and report dozens of distinct event types, from the creation of a new order to its modification, routing, and execution.

The technical specifications for these reports are highly detailed, requiring firms to populate numerous fields that did not exist in the OATS framework. For example, firms must now report whether an order was handled on a discretionary basis or whether it was part of a larger average price order.

The following table provides a simplified comparison of how a basic order workflow might be reported under OATS versus CAT, highlighting the increased complexity in execution.

| Order Workflow Step | OATS Reporting Execution | CAT Reporting Execution |
| --- | --- | --- |
| Customer Places Order | A ‘New Order Report’ (Type 1) is created and submitted. | A ‘New Order Event’ (MEO) is created, including the FDID and other detailed attributes. |
| Order Routed to Exchange | A ‘Route Report’ (Type 2) is submitted. | An ‘Order Route Event’ (MEOR) is reported, specifying the venue and route details. |
| Partial Execution | An ‘Execution Report’ (Type 4) is submitted for the partial fill. | An ‘Order Fulfillment Event’ (MEOF) is reported for the partial execution, linked to the original order. |
| Order is Cancelled | A ‘Cancel Report’ (Type 5) is submitted for the remaining shares. | An ‘Order Cancel Event’ (MEOC) is reported for the remaining portion of the order. |

![A precision sphere, an Execution Management System EMS, probes a Digital Asset Liquidity Pool. This signifies High-Fidelity Execution via Smart Order Routing for institutional-grade digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/principal-rfq-engine-orchestrating-global-digital-asset-derivatives-liquidity-pool-price-discovery-and-high-fidelity-execution.jpg)

## Synchronization and Error Correction

The execution of CAT reporting is also governed by far stricter technical standards for [clock synchronization](https://prime.greeks.live/area/clock-synchronization/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). While OATS had synchronization requirements, CAT mandates that all business clocks used to record order event times be synchronized to within 50 milliseconds of the National Institute of Standards and Technology (NIST) atomic clock. This requires firms to invest in more sophisticated clock synchronization technology and to implement rigorous monitoring to ensure compliance. The penalty for non-compliance is severe, as inaccurate timestamps can corrupt the entire audit trail.

Finally, the error correction process under CAT is more demanding. The system is designed to create a complete and accurate record of the [order lifecycle](https://prime.greeks.live/area/order-lifecycle/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) by the reporting deadline each day. This means that firms have a limited window to correct errors in their submissions. The interdependencies between different firms’ reports ▴ where one firm’s route report must match another firm’s new order report ▴ mean that errors can have a cascading effect.

The execution of CAT reporting, therefore, requires a level of operational excellence and system stability that goes well beyond the requirements of the OATS framework. The retirement of OATS is contingent on firms achieving a consistently low error rate in their CAT submissions, a testament to the high bar for execution in this new regulatory environment.

- **System Overhaul** ▴ Firms must transition from legacy systems designed for OATS to new or heavily modified platforms capable of handling CAT’s complex data requirements.

- **Data Governance** ▴ The implementation of FDIDs and the CAIS requires a new level of rigor in managing customer data and ensuring its accuracy.

- **Clock Synchronization** ▴ The 50-millisecond synchronization requirement necessitates investment in and monitoring of advanced timekeeping technology.

- **Inter-firm Linkage** ▴ The execution of reporting must account for the fact that a firm’s data will be linked and compared with data from other market participants, requiring a high degree of accuracy to avoid breaks in the audit trail.

![A spherical, eye-like structure, an Institutional Prime RFQ, projects a sharp, focused beam. This visualizes high-fidelity execution via RFQ protocols for digital asset derivatives, enabling block trades and multi-leg spreads with capital efficiency and best execution across market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/institutional-grade-prime-os-rfq-protocol-digital-asset-derivatives-block-trade-execution.jpg)

## References

- Broadridge Financial Solutions. “CAT vs. OATS.” Broadridge, 2019.

- “SEC Rule 613 ▴ Consolidated Audit Trail (CAT) OATS ▴ CAT Gap Analysis.” U.S. Securities and Exchange Commission, 2016.

- “OATS to CAT FAQ Mapping Exercise.” CAT NMS Plan, 2019.

- Harris, Larry. “Trading and Exchanges ▴ Market Microstructure for Practitioners.” Oxford University Press, 2003.

- O’Hara, Maureen. “Market Microstructure Theory.” Blackwell Publishers, 1995.

![A sleek green probe, symbolizing a precise RFQ protocol, engages a dark, textured execution venue, representing a digital asset derivatives liquidity pool. This signifies institutional-grade price discovery and high-fidelity execution through an advanced Prime RFQ, minimizing slippage and optimizing capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/digital-asset-derivatives-rfq-protocol-integration-for-high-fidelity-execution-and-institutional-liquidity-aggregation-on-prime-os.jpg)

## Reflection

The transition from OATS to CAT is more than a technical upgrade; it is a shift in the philosophy of market oversight. The knowledge of these technical differences provides a blueprint for understanding the current regulatory architecture. Reflect on your own operational framework. Are your data capture, timestamping, and reporting systems merely compliant, or are they architected to provide the kind of high-fidelity data that CAT now demands?

Viewing your firm’s data not as a regulatory burden, but as a strategic asset, is the first step toward building a truly resilient and intelligent operational model. The level of precision demanded by this new system offers a new potential for internal analysis and operational improvement.

![An abstract, precision-engineered mechanism showcases polished chrome components connecting a blue base, cream panel, and a teal display with numerical data. This symbolizes an institutional-grade RFQ protocol for digital asset derivatives, ensuring high-fidelity execution, price discovery, multi-leg spread processing, and atomic settlement within a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-precision-execution-1.jpg)

## Glossary

<a href="https://prime.greeks.live/area/consolidated-audit-trail/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Abstract geometric design illustrating a central RFQ aggregation hub for institutional digital asset derivatives. Radiating lines symbolize high-fidelity execution via smart order routing across dark pools](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-high-fidelity-execution-architecture.jpg)

## Consolidated Audit Trail

Meaning ▴ The Consolidated Audit Trail (CAT) is a comprehensive, centralized database designed to capture and track every order, quote, and trade across US equity and options markets. </a><a href="https://prime.greeks.live/area/order-audit-trail-system/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A luminous digital market microstructure diagram depicts intersecting high-fidelity execution paths over a transparent liquidity pool. A central RFQ engine processes aggregated inquiries for institutional digital asset derivatives, optimizing price discovery and capital efficiency within a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocols-high-fidelity-execution-principal-operational-framework-price-discovery.jpg)

## Order Audit Trail System

Meaning ▴ The Order Audit Trail System, or OATS, is a highly specialized data capture and reporting mechanism designed to provide a comprehensive, immutable record of an order's lifecycle within a trading system, from its inception through modification, routing, execution, or cancellation. </a><a href="https://prime.greeks.live/area/securities-and-exchange-commission/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A dark central hub with three reflective, translucent blades extending. This represents a Principal's operational framework for digital asset derivatives, processing aggregated liquidity and multi-leg spread inquiries](https://options.greeks.live/wp-content/uploads/2025/07/institutional-rfq-protocol-engine-for-high-fidelity-digital-asset-derivatives.jpg)

## Securities and Exchange Commission

Meaning ▴ The Securities and Exchange Commission, or SEC, operates as a federal agency tasked with protecting investors, maintaining fair and orderly markets, and facilitating capital formation within the United States. </a><a href="https://prime.greeks.live/question/how-do-firms-typically-manage-the-synchronization-of-timestamps-across-different-trading-systems-for-cat-reporting/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Polished metallic pipes intersect via robust fasteners, set against a dark background. This symbolizes intricate Market Microstructure, RFQ Protocols, and Multi-Leg Spread execution](https://options.greeks.live/wp-content/uploads/2025/07/precision-engineered-metallic-nodes-illustrating-rfq-protocols-for-multi-leg-digital-asset-derivatives-institutional-execution.jpg)

## Different Firms

Firms manage CAT timestamp synchronization by deploying a hierarchical timing architecture traceable to NIST, typically using NTP or PTP. </a><a href="https://prime.greeks.live/question/how-does-the-ccp-default-waterfall-protect-non-defaulting-members/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A precisely balanced transparent sphere, representing an atomic settlement or digital asset derivative, rests on a blue cross-structure symbolizing a robust RFQ protocol or execution management system. This setup is anchored to a textured, curved surface, depicting underlying market microstructure or institutional-grade infrastructure, enabling high-fidelity execution, optimized price discovery, and capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-engineered-rfq-block-trade-execution-for-digital-asset-derivatives.jpg)

## Finra Members

A CCP's default waterfall shields non-defaulting members by sequentially activating layers of financial resources to absorb and contain a defaulter's losses. </a><a href="https://prime.greeks.live/area/finra/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Two dark, circular, precision-engineered components, stacked and reflecting, symbolize a Principal's Operational Framework. This layered architecture facilitates High-Fidelity Execution for Block Trades via RFQ Protocols, ensuring Atomic Settlement and Capital Efficiency within Market Microstructure for Digital Asset Derivatives](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-prime-os-execution-protocol.jpg)

## Finra

Meaning ▴ FINRA, the Financial Industry Regulatory Authority, functions as the largest independent regulator for all securities firms conducting business in the United States. </a><a href="https://prime.greeks.live/area/audit-trail/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Intersecting concrete structures symbolize the robust Market Microstructure underpinning Institutional Grade Digital Asset Derivatives. Dynamic spheres represent Liquidity Pools and Implied Volatility](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-framework-optimizing-rfq-execution-and-liquidity-for-principal-trading.jpg)

## Audit Trail

Meaning ▴ An Audit Trail is a chronological, immutable record of system activities, operations, or transactions within a digital environment, detailing event sequence, user identification, timestamps, and specific actions. </a><a href="https://prime.greeks.live/area/firm-designated-id/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A focused view of a robust, beige cylindrical component with a dark blue internal aperture, symbolizing a high-fidelity execution channel. This element represents the core of an RFQ protocol system, enabling bespoke liquidity for Bitcoin Options and Ethereum Futures, minimizing slippage and information leakage](https://options.greeks.live/wp-content/uploads/2025/07/institutional-grade-digital-asset-derivatives-rfq-engine-core-precision-component.jpg)

## Firm Designated Id

Meaning ▴ The Firm Designated ID represents a unique alphanumeric identifier assigned by an executing institution to each order or trade initiated within its proprietary systems. </a><a href="https://prime.greeks.live/area/cat-reporting/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sophisticated apparatus, potentially a price discovery or volatility surface calibration tool. A blue needle with sphere and clamp symbolizes high-fidelity execution pathways and RFQ protocol integration within a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-rfq-protocol-institutional-digital-asset-derivatives-execution.jpg)

## Cat Reporting

Meaning ▴ CAT Reporting, or Consolidated Audit Trail Reporting, mandates the comprehensive capture and reporting of all order and trade events across US equity and and options markets. </a><a href="https://prime.greeks.live/area/clock-synchronization/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Abstract architectural representation of a Prime RFQ for institutional digital asset derivatives, illustrating RFQ aggregation and high-fidelity execution. Intersecting beams signify multi-leg spread pathways and liquidity pools, while spheres represent atomic settlement points and implied volatility](https://options.greeks.live/wp-content/uploads/2025/07/architecting-institutional-digital-asset-derivatives-trading-systems-for-optimized-rfq-execution-and-advanced-price-discovery.jpg)

## Clock Synchronization

Meaning ▴ Clock Synchronization refers to the process of aligning the internal clocks of independent computational systems within a distributed network to a common time reference. </a><a href="https://prime.greeks.live/area/order-lifecycle/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A transparent blue sphere, symbolizing precise Price Discovery and Implied Volatility, is central to a layered Principal's Operational Framework. This structure facilitates High-Fidelity Execution and RFQ Protocol processing across diverse Aggregated Liquidity Pools, revealing the intricate Market Microstructure of Institutional Digital Asset Derivatives](https://options.greeks.live/wp-content/uploads/2025/07/digital-asset-derivatives-rfq-execution-system-microstructure-principal-framework.jpg)

## Order Lifecycle

Meaning ▴ The Order Lifecycle represents the comprehensive, deterministic sequence of states an institutional order transitions through, from its initial generation and submission to its ultimate execution, cancellation, or expiration within the digital asset derivatives market. </a>

**Tags:** [Consolidated Audit Trail](https://options.greeks.live/area/consolidated-audit-trail/), [SEC Rule 613](https://options.greeks.live/area/sec-rule-613/), [NMS Securities](https://options.greeks.live/area/nms-securities/), [Clock Synchronization](https://options.greeks.live/area/clock-synchronization/), [Market Microstructure](https://options.greeks.live/area/market-microstructure/), [CAT Reporting](https://options.greeks.live/area/cat-reporting/)	

## Discover More

- 
### [What Are the Regulatory Implications of Reporting Block Trades Executed via RFQ?](https://options.greeks.live/question/what-are-the-regulatory-implications-of-reporting-block-trades-executed-via-rfq/)
![A precision-engineered, multi-layered system component, symbolizing the intricate market microstructure of institutional digital asset derivatives. Two distinct probes represent RFQ protocols for price discovery and high-fidelity execution, integrating latent liquidity and pre-trade analytics within a robust Prime RFQ framework, ensuring best execution.](https://options.greeks.live/wp-content/uploads/2025/08/digital-asset-derivatives-rfq-protocols-high-fidelity-execution.jpg)

Reporting RFQ block trades is a calibrated disclosure process, balancing execution needs with market integrity through delayed, detailed reporting.

- 
### [What Data Points Are Most Critical for Accurate Block Trade Reporting?](https://options.greeks.live/question/what-data-points-are-most-critical-for-accurate-block-trade-reporting/)
![A blue speckled marble, symbolizing a precise block trade, rests centrally on a translucent bar, representing a robust RFQ protocol. This structured geometric arrangement illustrates complex market microstructure, enabling high-fidelity execution, optimal price discovery, and efficient liquidity aggregation within a principal's operational framework for institutional digital asset derivatives.](https://options.greeks.live/wp-content/uploads/2025/07/precision-institutional-rfq-execution-framework-optimizing-digital-asset-derivatives-liquidity-aggregation-across-complex-market-microstructure.jpg)

Accurate block trade reporting hinges on the precise capture of execution, participant, and handling data to ensure market integrity.

- 
### [What Are the Primary Compliance and Auditing Advantages of Using FIX for RFQ Negotiations?](https://options.greeks.live/question/what-are-the-primary-compliance-and-auditing-advantages-of-using-fix-for-rfq-negotiations/)
![Abstract institutional-grade Crypto Derivatives OS. Metallic trusses depict market microstructure. Transparent discs symbolize liquidity pools, implied volatility, and dark pools, crucial for RFQ protocols and block trade execution. This visualizes high-fidelity execution and price discovery for digital asset derivatives.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-market-microstructure-optimizing-rfq-protocols-for-high-fidelity-execution-via-prime-os.jpg)

FIX for RFQ embeds an immutable, timestamped audit trail into the negotiation workflow, ensuring evidentiary certainty for compliance.

- 
### [How Do Regulators View the Growth of Dark Pools and Its Impact on Market Fairness?](https://options.greeks.live/question/how-do-regulators-view-the-growth-of-dark-pools-and-its-impact-on-market-fairness/)
![Two smooth, teal spheres, representing institutional liquidity pools, precisely balance a metallic object, symbolizing a block trade executed via RFQ protocol. This depicts high-fidelity execution, optimizing price discovery and capital efficiency within a Principal's operational framework for digital asset derivatives.](https://options.greeks.live/wp-content/uploads/2025/07/precision-execution-bridging-institutional-liquidity-pools-via-rfq-protocol-for-optimized-digital-asset-derivatives-price-discovery.jpg)

Regulators balance the need for institutional trading discretion with the mandate for fair, transparent public markets.

- 
### [Which Regulatory Frameworks Govern the Use of Advanced Technologies in Block Trade Execution?](https://options.greeks.live/question/which-regulatory-frameworks-govern-the-use-of-advanced-technologies-in-block-trade-execution/)
![A multi-layered electronic system, centered on a precise circular module, visually embodies an institutional-grade Crypto Derivatives OS. It represents the intricate market microstructure enabling high-fidelity execution via RFQ protocols for digital asset derivatives, driven by an intelligence layer facilitating algorithmic trading and optimal price discovery.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-engine-facilitating-high-fidelity-execution-and-optimal-price-discovery.jpg)

Advanced technology in block trade execution is governed by frameworks mandating transparency, best execution, and anti-manipulation to ensure market integrity.

- 
### [What Are the Key Differences in FIX-Based Compliance Reporting between MiFID II and CAT?](https://options.greeks.live/question/what-are-the-key-differences-in-fix-based-compliance-reporting-between-mifid-ii-and-cat/)
![A digitally rendered, split toroidal structure reveals intricate internal circuitry and swirling data flows, representing the intelligence layer of a Prime RFQ. This visualizes dynamic RFQ protocols, algorithmic execution, and real-time market microstructure analysis for institutional digital asset derivatives.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-core-processing-architecture-visualized-through-interconnected-liquidity-networks.jpg)

MiFID II and CAT differ in that MiFID II uses FIX for transaction-based reporting to a decentralized EU network, while CAT mandates reporting every order event to a centralized US database.

- 
### [How Does the Consolidated Audit Trail Change Best Execution Oversight for HFT?](https://options.greeks.live/question/how-does-the-consolidated-audit-trail-change-best-execution-oversight-for-hft/)
![A futuristic, intricate central mechanism with luminous blue accents represents a Prime RFQ for Digital Asset Derivatives Price Discovery. Four sleek, curved panels extending outwards signify diverse Liquidity Pools and RFQ channels for Block Trade High-Fidelity Execution, minimizing Slippage and Latency in Market Microstructure operations.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-platform-2.jpg)

The Consolidated Audit Trail elevates best execution from a qualitative duty to a quantitative proof, verifiable at the nanosecond level.

- 
### [What Are the Regulatory Considerations and Concerns Surrounding the Use of Size Priority in Dark Pools?](https://options.greeks.live/question/what-are-the-regulatory-considerations-and-concerns-surrounding-the-use-of-size-priority-in-dark-pools/)
![A central, blue-illuminated, crystalline structure symbolizes an institutional grade Crypto Derivatives OS facilitating RFQ protocol execution. Diagonal gradients represent aggregated liquidity and market microstructure converging for high-fidelity price discovery, optimizing multi-leg spread trading for digital asset options.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-engine-11.jpg)

Regulatory concerns over size priority in dark pools center on balancing block liquidity benefits against risks to fairness and price discovery.

- 
### [What Is the Current Regulatory Landscape Surrounding High-Frequency Trading and Front-Running Practices?](https://options.greeks.live/question/what-is-the-current-regulatory-landscape-surrounding-high-frequency-trading-and-front-running-practices/)
![A chrome cross-shaped central processing unit rests on a textured surface, symbolizing a Principal's institutional grade execution engine. It integrates multi-leg options strategies and RFQ protocols, leveraging real-time order book dynamics for optimal price discovery in digital asset derivatives, minimizing slippage and maximizing capital efficiency.](https://options.greeks.live/wp-content/uploads/2025/07/principals-high-fidelity-rfq-execution-digital-asset-derivatives-hub.jpg)

The regulatory landscape for HFT is a dual framework of U.S. post-trade data surveillance and E.U. pre-trade system governance.

---

## Raw Schema Data

```json
{
    "@context": "https://schema.org",
    "@type": "BreadcrumbList",
    "itemListElement": [
        {
            "@type": "ListItem",
            "position": 1,
            "name": "Home",
            "item": "https://options.greeks.live"
        },
        {
            "@type": "ListItem",
            "position": 2,
            "name": "Question",
            "item": "https://options.greeks.live/question/"
        },
        {
            "@type": "ListItem",
            "position": 3,
            "name": "How Does the CAT System Technically Differ from the Previous OATS Framework?",
            "item": "https://options.greeks.live/question/how-does-the-cat-system-technically-differ-from-the-previous-oats-framework/"
        }
    ]
}
```

```json
{
    "@context": "https://schema.org",
    "@type": "Organization",
    "@id": "https://greeks.live/#organization",
    "name": "Greeks.Live",
    "url": "https://greeks.live/",
    "description": "Greeks.live is the definitive toolkit for the professional options trader, dedicated to empowering our users with institutional-grade data, advanced analytics, and a comprehensive suite of trading tools designed to provide a decisive edge in the market. Every article and guide published under the Greeks.live name is a product of our deep commitment to data-driven analysis and our mission to support the global trading community.",
    "email": "support@greeks.live",
    "logo": {
        "@type": "ImageObject",
        "url": "https://options.greeks.live/wp-content/uploads/2025/07/Greeks.Live-Logo-Icon.svg"
    },
    "hasPart": [
        {
            "@type": "WebSite",
            "name": "About Us",
            "url": "https://about.greeks.live"
        },
        {
            "@type": "WebSite",
            "name": "App Download Page",
            "url": "https://about.greeks.live/#/download/basic_trade"
        },
        {
            "@type": "WebSite",
            "name": "Newcomers' Guide",
            "url": "https://twisty-sign-c8b.notion.site/Guide-for-Greeks-live-X-Deribit-Newbies-5a08a3052822427d800af6eaf3704c8d"
        },
        {
            "@type": "WebSite",
            "name": "Knowledge Base",
            "url": "https://linktr.ee/greeks.live"
        },
        {
            "@type": "WebSite",
            "name": "Option Terminology",
            "url": "https://greekslive.notion.site/88dfc00e7c584d4d8969b6302a79a12f?pvs=4"
        },
        {
            "@type": "WebSite",
            "name": "Terms of Service",
            "url": "https://greeks.live/#/tos"
        },
        {
            "@type": "WebSite",
            "name": "Disclaimer",
            "url": "https://greeks.live/#/disclaimer"
        }
    ],
    "sameAs": [
        "https://x.com/greekslive",
        "https://youtube.com/@greeks_live?si=-KjT0Lkw4WUCI0tD",
        "https://t.me/greekslive_notifications",
        "https://t.me/greekslive",
        "https://pinterest.com/greekslive/"
    ],
    "makesOffer": [
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "RFQ Platform",
                "url": "https://rfq.greeks.live",
                "description": "Execute institutional-grade block trades for crypto options and futures. This platform provides deep, over-the-counter (OTC) liquidity via a professional Request for Quote system.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Lending Tools",
                "url": "https://lend.greeks.live",
                "description": "Manage crypto lending and borrowing activities to earn yield or secure loans. This suite of tools helps users analyze interest rates and manage collateralized debt positions.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Data Lab",
                "url": "https://greeks.live/#/deribit/tools/datalab/BTC",
                "description": "Analyze historical and real-time options data with advanced metrics. This tool is designed for backtesting strategies and identifying market trends through comprehensive data visualization.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Profit & Loss Analysis (PnL)",
                "url": "https://greeks.live/#/deribit/tools/pnl_analysis",
                "description": "Track and analyze the Profit and Loss (PnL) of your options portfolio. This tool provides detailed performance metrics to help traders evaluate and refine their strategies.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Position Visualization",
                "url": "https://greeks.live/#/deribit/tools/pv/BTC",
                "description": "Visualize complex options positions and their corresponding risk profiles. This tool generates payoff diagrams to help traders intuitively understand potential profit, loss, and exposure.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Options Calculator",
                "url": "https://greeks.live/#/deribit/tools/calculator",
                "description": "Calculate the theoretical price and risk parameters ('the Greeks') of crypto options. An essential tool for pricing new trades and analyzing the sensitivity of existing positions.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Greeks.live Main Platform",
                "url": "https://greeks.live/",
                "description": "The central hub for the Greeks.live suite of professional cryptocurrency options and derivatives trading tools. Access analytics, manage positions, and explore the ecosystem.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Community Forum",
                "url": "https://t.greeks.live",
                "description": "Join the official Greeks.live community. Connect with other traders, share insights, and receive the latest updates directly from the team.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Greeks.live for Deribit",
                "url": "http://deribit.greeks.live",
                "description": "A dedicated interface for trading on the Deribit exchange. This platform leverages Greeks.live's advanced analytics and tools specifically for users of Deribit's options and futures markets.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Greeks.live for OKX",
                "url": "http://okx.greeks.live",
                "description": "A dedicated interface for trading on the OKX exchange. This platform integrates Greeks.live's powerful analytics with the OKX marketplace, focusing on its options and derivatives products.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "GLVS.AI Trading Platform",
                "url": "https://www.glvs.ai/",
                "description": "An AI-powered platform for automated crypto options trading. Leverage advanced algorithms and data-driven signals to develop and deploy sophisticated, hands-free trading strategies.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "API Testnet & Sandbox",
                "url": "https://test.greeks.live",
                "description": "A dedicated testnet environment for developers to test their API integrations and automated trading strategies. This sandbox allows for full functionality testing without risking real funds.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        }
    ],
    "subOrganization": [
        {
            "@type": "Organization",
            "name": "GreeksLive HK Co., Limited",
            "email": "support@greeks.live",
            "telephone": "+852-56418949",
            "address": {
                "@type": "PostalAddress",
                "streetAddress": "Unit 11, 27/F, K. Wah Centre, 191 Java Road",
                "addressLocality": "Hong Kong",
                "addressRegion": "North Point",
                "addressCountry": "CN",
                "postalCode": "0000"
            },
            "geo": {
                "@type": "GeoCoordinates",
                "latitude": "22.2932357",
                "longitude": "114.2022026"
            },
            "image": "https://options.greeks.live/wp-content/uploads/2025/08/Wah-Centre-Hong-Kong.jpg"
        }
    ]
}
```

```json
{
    "@context": "https://schema.org",
    "@type": "Article",
    "mainEntityOfPage": {
        "@type": "WebPage",
        "@id": "https://options.greeks.live/question/how-does-the-cat-system-technically-differ-from-the-previous-oats-framework/"
    },
    "headline": "How Does the CAT System Technically Differ from the Previous OATS Framework? \u25b4 Question",
    "description": "The CAT system technically differs from OATS by architecting a universal, full-lifecycle surveillance framework for all US markets. \u25b4 Question",
    "url": "https://options.greeks.live/question/how-does-the-cat-system-technically-differ-from-the-previous-oats-framework/",
    "datePublished": "2025-08-04T11:58:38+00:00",
    "dateModified": "2025-08-04T11:58:38+00:00",
    "articleSection": [
        "Question"
    ],
    "author": {
        "@id": "https://greeks.live/#organization"
    },
    "publisher": {
        "@id": "https://greeks.live/#organization"
    },
    "image": {
        "@type": "ImageObject",
        "url": "https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-protocol-execution-engine.jpg",
        "caption": "A precisely engineered abstract form symbolizes institutional digital asset derivatives trading. The elegant interaction of two distinct components visualizes the RFQ protocol lifecycle, from private quotation generation to block trade execution. It highlights high-fidelity execution and cross-venue liquidity aggregation within a Prime Brokerage OS, ensuring capital efficiency and minimal information leakage. This represents advanced algorithmic execution strategies and market microstructure optimization for atomic settlement of complex multi-leg spreads in a Principal-to-Principal framework."
    },
    "keywords": [
        "Audit Trail",
        "Broker-Dealer Operations",
        "CAT Reporting",
        "Clock Synchronization",
        "Consolidated Audit Trail",
        "FINRA",
        "Firm Designated ID",
        "Market Microstructure",
        "Market Surveillance",
        "NMS Securities",
        "Order Audit Trail System",
        "Order Lifecycle",
        "Regulatory Reporting",
        "SEC Rule 613",
        "Securities and Exchange Commission"
    ]
}
```

```json
{
    "@context": "https://schema.org",
    "@type": "WebSite",
    "url": "https://options.greeks.live/",
    "potentialAction": {
        "@type": "SearchAction",
        "target": "https://options.greeks.live/?s=search_term_string",
        "query-input": "required name=search_term_string"
    }
}
```


---

**Original URL:** https://options.greeks.live/question/how-does-the-cat-system-technically-differ-from-the-previous-oats-framework/
