# What Are the Primary Differences between Oats and Cat Reporting for Broker-Dealers? ▴ Question

**Published:** 2025-08-01
**Categories:** Question

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## 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 architectural evolution in market surveillance. It is an elevation from a jurisdictionally-specific, siloed audit mechanism to a holistic, national market structure monitoring system. To grasp the primary differences is to understand the shift in regulatory philosophy and technological capability. OATS was a system designed by a single self-regulatory organization, FINRA, to oversee its member firms’ activities in specific securities.

Its architecture, while effective for its purpose, was inherently limited by its jurisdictional boundaries and the scope of data it was designed to collect. It provided a necessary, yet incomplete, picture of the market’s intricate order flow.

CAT, mandated by the SEC under Rule 613, is an entirely different construct. It was conceived in the aftermath of market structure events that revealed the deep fragmentation of the U.S. equity and options markets. The core design principle of CAT is the creation of a single, comprehensive data repository for the entire lifecycle of every order, quote, and trade across all U.S. exchanges and alternative trading systems. This is not a mere upgrade; it is a systemic re-architecture.

The system’s objective is to provide regulators with an unprecedented and granular view of market behavior, enabling them to reconstruct market events, surveil for manipulative activity, and analyze the health of the market’s plumbing with a fidelity that was previously unattainable. The primary distinctions between the two systems are therefore not just in the data fields they collect, but in their foundational purpose, scope, and the technological demands they place on the industry.

> The move from OATS to CAT is a shift from a limited, single-regulator audit system to a comprehensive, national market surveillance architecture.

Understanding this transition requires an appreciation for the operational realities of a broker-dealer. Under OATS, a firm’s reporting obligation was confined to its activities within [FINRA](https://prime.greeks.live/area/finra/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite)’s purview. This created a [reporting framework](https://prime.greeks.live/question/what-is-the-role-of-an-approved-reporting-mechanism-arm-in-the-mifir-transaction-reporting-protocol/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) that, while demanding, was bounded. With CAT, the perimeter has dissolved.

Every broker-dealer, regardless of its size or business model, is now a node in a national data network. The system captures not just equities, but [listed options](https://prime.greeks.live/area/listed-options/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite), expanding the surveillance aperture significantly. This expansion is most evident in the level of detail required. CAT mandates the reporting of customer-identifying information, a critical element for tracing order flow from its ultimate origin.

It requires the capture of complex allocation workflows and a more precise timestamping of manual order handling events. These are not incremental changes. They represent a new paradigm of regulatory data intensity, demanding a complete re-evaluation of a firm’s [data capture](https://prime.greeks.live/area/data-capture/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite), storage, and reporting infrastructure. The architectural challenge for a broker-dealer is to build systems that can meet this new standard of granularity and completeness, transforming a compliance function into a core operational capability.

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## What Is the Fundamental Difference in Scope?

The fundamental difference in scope between OATS and CAT lies in their jurisdictional and product coverage. OATS was a FINRA-mandated system, and its reach was therefore limited to FINRA member firms and their activities in NASDAQ and OTC equity securities. This created a powerful, yet circumscribed, view of the market. It was an [audit trail](https://prime.greeks.live/area/audit-trail/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) for a significant portion of the market, but a portion nonetheless.

This jurisdictional limitation meant that order flow originating from or routed through non-FINRA member entities, or activity in other asset classes like listed options, was outside its purview. The system was designed to address the regulatory needs of a single SRO, and its architecture reflected this focused mandate.

CAT, by contrast, was established by the SEC to create a unified surveillance system across the entirety of the U.S. national market system. Its scope is universal. It applies to every broker-dealer registered with the SEC, regardless of their SRO affiliation. There are no exemptions.

A firm that was previously exempt from OATS reporting because it routed all its orders to another member firm now has a direct reporting obligation to CAT. This universality is the system’s defining feature. It is designed to eliminate the regulatory seams that existed in the previous framework. The product scope is similarly expansive, covering all NMS stocks, listed options, and OTC equities.

This comprehensive coverage ensures that regulators can follow an order’s journey from inception to execution, regardless of the venues it traverses or the asset class it represents. This shift from a limited, SRO-specific system to a universal, national one is the most profound difference between the two reporting regimes.

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## How Does Data Granularity Differ?

The divergence in [data granularity](https://prime.greeks.live/area/data-granularity/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) between OATS and CAT is a direct consequence of their differing architectural goals. OATS was designed to provide an audit trail of order events. It captured essential information about the lifecycle of an order ▴ its origination, routing, modification, and execution.

While detailed, the data requirements were tailored to FINRA’s surveillance needs and focused primarily on the actions of the broker-dealer handling the order. The system was effective at tracking the sequence of events for a given order within its reporting universe.

CAT, with its mandate to create a comprehensive reconstruction of market activity, demands a far deeper and more granular dataset. The system is not just tracking order events; it is building a complete, interconnected map of market participation. This requires the collection of data points that were outside the scope of OATS. The most significant of these is the requirement to link orders to specific customers through a [Firm Designated ID](https://prime.greeks.live/area/firm-designated-id/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (FDID).

This allows regulators to trace activity back to its source, providing a powerful tool for identifying coordinated manipulative behavior. CAT also requires the reporting of detailed allocation information, which is critical for understanding how large block trades are distributed among various accounts. The requirements for timestamping manual events are more stringent, mandating the capture of two timestamps to more accurately reflect the duration of the handling process. Furthermore, CAT expands the reporting of quoting activity, particularly in the OTC equity space, providing a more complete picture of pre-trade liquidity.

This leap in granularity transforms the nature of the reporting obligation. It is a move from event-based reporting to a more holistic, relationship-based data submission model, where the connections between orders, customers, and allocations are as important as the events themselves.

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## Strategy

The strategic implications of the transition from OATS to CAT for a broker-dealer are profound, extending far beyond the mere technical challenge of reporting additional data fields. The shift necessitates a fundamental re-evaluation of a firm’s data governance, technology architecture, and [compliance framework](https://prime.greeks.live/area/compliance-framework/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). Under OATS, the reporting process could often be managed as a distinct, end-of-day function, handled by a specific team responsible for generating and submitting the required files.

The system’s limitations and known parameters allowed for a relatively contained and predictable compliance workflow. The strategic focus was on ensuring the accuracy and timeliness of a well-defined data set for a specific regulator.

CAT disrupts this model entirely. Its comprehensive scope and near-real-time reporting expectations demand that compliance be woven into the very fabric of a firm’s trading and operational infrastructure. It is a continuous, system-wide process. The strategic challenge is to build an integrated data ecosystem where every order event, from every system, is captured, enriched, and validated in a manner that is consistent with CAT’s complex requirements.

This requires a move away from siloed [data sources](https://prime.greeks.live/area/data-sources/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) and batch processing toward a more unified and event-driven architecture. The firm’s Order Management System (OMS), Execution Management System (EMS), and any proprietary trading systems must now be viewed as components of a larger regulatory reporting engine. The data they generate must be harmonized, and the linkages between different events and entities must be preserved with absolute fidelity.

> CAT transforms regulatory reporting from a siloed, end-of-day task into a continuous, firm-wide data integrity challenge.

This architectural shift presents both challenges and opportunities. The primary challenge is the significant investment required in technology and expertise. Firms must develop or procure systems capable of handling the massive volume and complexity of [CAT data](https://prime.greeks.live/area/cat-data/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). They must also cultivate a deeper understanding of the entire order lifecycle, from the client’s initial instruction to the final allocation.

This requires a collaborative effort between compliance, technology, and business teams. The opportunity, however, is the creation of a valuable strategic asset ▴ a clean, comprehensive, and near-real-time repository of the firm’s own trading activity. This “golden source” of data can be leveraged for more than just regulatory reporting. It can be used for enhanced trade surveillance, more sophisticated [transaction cost analysis](https://prime.greeks.live/area/transaction-cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (TCA), and improved risk management. By building a robust [CAT reporting](https://prime.greeks.live/area/cat-reporting/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) framework, a firm is also building a powerful business intelligence engine that can provide a decisive operational edge.

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## Comparing Reporting Frameworks

To fully appreciate the strategic shift, it is useful to compare the OATS and CAT reporting frameworks across several key dimensions. This comparison highlights the increased complexity and the need for a more integrated approach under CAT.

### Reporting Framework Comparison OATS vs CAT

| Dimension | OATS Framework | CAT Framework |
| --- | --- | --- |
| Applicability | FINRA member firms only. | All U.S. registered broker-dealers. |
| Product Scope | NASDAQ and OTC equities. | NMS stocks, listed options, OTC equities. |
| Customer Data | No direct customer identifiers required. | Firm Designated ID (FDID) required, linking orders to customers. |
| Data Linkage | Primarily focused on the sequence of events for a single order. | Requires complex linkage of orders, routes, executions, and allocations. |
| Error Correction | More lenient error correction timeline. | Shorter T+3 error correction window. |
| Reporting Model | Primarily a batch-based, end-of-day process. | Near-real-time reporting, requiring an event-driven architecture. |

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## Strategic Considerations for Implementation

The implementation of a CAT reporting solution is a major strategic undertaking. It requires a firm to think holistically about its data infrastructure and compliance processes. The following are key strategic considerations:

- 
**Data Sourcing and Integration** A firm must identify every system that originates or handles order-related data. This includes not only the primary OMS and EMS platforms but also proprietary systems, risk management tools, and even manual order ticket systems. A strategy must be developed to capture data from these disparate sources in a consistent and reliable manner. This often involves the creation of a central data hub or “data lake” where information can be aggregated, normalized, and enriched before being formatted for CAT submission.

- 
**Clock Synchronization** The timestamping requirements of CAT are incredibly precise. All systems involved in the order lifecycle must be synchronized to a common time source, typically the National Institute of Standards and Technology (NIST). This is a critical technical requirement that has significant strategic implications.
It necessitates a firm-wide clock synchronization policy and the technology to enforce it. Failure to achieve and maintain accurate synchronization can lead to persistent reporting errors and regulatory scrutiny.

- 
**Error Management and Reconciliation** Given the complexity of CAT and its shorter correction window, a robust error management process is essential. This process must be able to identify, research, and correct errors quickly and efficiently. This requires a sophisticated reconciliation framework that can compare the data submitted to CAT with the firm’s internal records and with data reported by other market participants. The strategy should focus on proactive error prevention through rigorous data validation and pre-submission checks, rather than reactive correction.

- 
**Vendor vs. In-House Build** Firms face a critical strategic choice ▴ build their own CAT reporting solution or partner with a third-party vendor. A custom-built solution offers the potential for greater control and integration with existing systems, but it also requires a significant upfront investment in development and ongoing maintenance.
A vendor solution can provide a faster path to compliance and leverage the expertise of a specialized provider, but it may offer less flexibility and create a dependency on a third party. The right strategy depends on the firm’s size, complexity, and internal technology capabilities.

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## Execution

The execution of a compliant CAT reporting framework is a complex, multi-stage process that demands meticulous planning and flawless technological implementation. It is where the strategic vision for data governance and compliance is translated into a functioning operational reality. The core of the execution challenge lies in building a system that can reliably perform three critical functions ▴ capture, enrichment, and submission.

This system must be able to ingest a high volume of diverse data from multiple sources, intelligently enrich that data with the specific information required by CAT, and then format and submit it to the central repository in a timely and accurate manner. This is a data engineering problem of the highest order, requiring a deep understanding of both the firm’s internal systems and the technical specifications of the [CAT NMS Plan](https://prime.greeks.live/area/cat-nms-plan/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite).

The execution phase begins with a detailed mapping of the firm’s order flows. Every possible path an order can take, from its initial receipt from a client to its final execution and allocation, must be documented and analyzed. This mapping exercise is essential for identifying all the “reportable events” that must be captured and submitted to CAT. For each event, the firm must identify the source system that generates the relevant data and the specific data elements that need to be extracted.

This process often reveals gaps in existing data capture capabilities, which must be remediated through system enhancements or the implementation of new data capture tools. The goal is to create a complete and unambiguous “source of truth” for every piece of data that will be reported to CAT.

> A successful CAT implementation hinges on the ability to translate complex regulatory requirements into a robust and automated data processing pipeline.

Once the data sources have been identified and the capture mechanisms are in place, the focus shifts to data enrichment. This is perhaps the most complex part of the execution process. Raw data from the firm’s systems must be transformed and augmented to meet CAT’s specific requirements. This includes assigning unique identifiers to orders and routes, linking child orders to their parent orders, and, most critically, associating orders with the correct Firm Designated ID (FDID).

The enrichment process requires a sophisticated rules engine that can apply the complex logic of the CAT specifications to the firm’s data. This engine must be able to handle a wide variety of scenarios, from simple single-order executions to complex multi-leg option strategies and allocated block trades. The accuracy of this enrichment process is paramount, as any errors will cascade through the reporting chain and lead to costly and time-consuming corrections.

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## The Operational Playbook

A successful CAT reporting implementation requires a detailed operational playbook that outlines the key steps and responsibilities. This playbook serves as a guide for the project team and ensures that all aspects of the implementation are addressed in a systematic and coordinated manner.

- 
**Establish a Governance Framework** The first step is to establish a clear governance structure for the CAT implementation project. This includes forming a cross-functional project team with representation from compliance, technology, operations, and the business lines. A project sponsor should be appointed to provide executive oversight and ensure that the project receives the necessary resources. The governance framework should also define the roles and responsibilities of each team member and establish a clear process for decision-making and issue escalation.

- 
**Conduct a Comprehensive Gap Analysis** A thorough gap analysis is essential for understanding the scope of the implementation effort. This analysis should compare the firm’s existing data capture and reporting capabilities with the detailed requirements of the CAT [NMS Plan](https://prime.greeks.live/area/nms-plan/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). The output of this analysis should be a detailed list of all the gaps that need to be addressed, along with a plan for remediation. This may involve modifying existing systems, implementing new technologies, or changing business processes.

- 
**Develop a Detailed Technical Architecture** Based on the results of the gap analysis, the firm must develop a detailed technical architecture for its CAT reporting solution. This architecture should specify the systems, databases, and data flows that will be used to capture, enrich, and submit CAT data. It should also address key technical requirements such as clock synchronization, data storage, and security. The architecture should be designed to be scalable, resilient, and flexible enough to accommodate future changes to the CAT reporting requirements.

- 
**Build and Test the Solution** With the architecture defined, the development and testing phase can begin. This is an iterative process that involves building the necessary software components, integrating them with the firm’s existing systems, and rigorously testing the end-to-end solution. Testing should be comprehensive, covering a wide range of scenarios and data volumes.
It should include unit testing, integration testing, and user acceptance testing. The firm should also participate in the industry-wide testing programs organized by the [CAT NMS](https://prime.greeks.live/area/cat-nms/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) Plan operator.

- 
**Deploy and Monitor the Solution** Once the solution has been thoroughly tested and certified, it can be deployed into production. The deployment should be carefully planned and executed to minimize disruption to the firm’s operations. After deployment, the solution must be continuously monitored to ensure that it is operating correctly and that the data being submitted to CAT is accurate and complete. This includes monitoring for system errors, data quality issues, and any changes in the firm’s order flows that might impact the reporting process.

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## Quantitative Modeling and Data Analysis

The transition to CAT introduces new opportunities for quantitative modeling and data analysis. The rich, granular dataset collected for CAT can be used to develop more sophisticated models for transaction cost analysis (TCA), risk management, and algorithmic trading. By leveraging this data, firms can gain deeper insights into their execution quality and identify opportunities for improvement.

### Sample CAT Data for TCA Modeling

| Event Timestamp | FDID | Symbol | Order Type | Quantity | Route Destination | Execution Price | Arrival Price (VWAP) |
| --- | --- | --- | --- | --- | --- | --- | --- |
| 2025-08-01 09:30:01.123456 | CUST_123 | XYZ | Market | 10000 | SMART | 100.02 | 100.01 |
| 2025-08-01 09:30:02.456789 | CUST_123 | XYZ | Fill | 5000 | NYSE | 100.03 | 100.02 |
| 2025-08-01 09:30:03.789012 | CUST_123 | XYZ | Fill | 5000 | NASDAQ | 100.01 | 100.02 |

The data in the table above can be used to calculate various TCA metrics, such as implementation shortfall and price improvement. For example, the implementation shortfall for this order can be calculated as the difference between the average execution price and the arrival price, multiplied by the quantity. This analysis can be performed at the individual order level, or aggregated across different clients, strategies, or traders to identify patterns and trends. By combining CAT data with other market data sources, firms can build sophisticated models that can predict execution costs, optimize routing strategies, and detect potential market abuse.

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## References

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

- Securities Industry and Financial Markets Association. “Firm’s Guide to the Consolidated Audit Trail.” SIFMA.

- InfoReach, Inc. “Sunset of OATS.” InfoReach, 14 Sept. 2021.

- CAT NMS Plan. “Frequently Asked Questions.” CATNMSPLAN.com.

- Financial Industry Regulatory Authority. “CAT FAQ for Small Firms.” FINRA.org.

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## Reflection

The architectural shift from OATS to CAT is complete. The industry has absorbed the initial shock of implementation, and the flow of data into the consolidated repository is now a daily operational reality. The question for a forward-thinking broker-dealer is no longer “How do we comply?” but “What does this new level of transparency enable?” The system, born of a regulatory mandate for comprehensive surveillance, has created a secondary, and perhaps more potent, effect.

It has forced every market participant to create a high-fidelity digital record of their own activity. This internal data asset, a byproduct of compliance, holds immense strategic value.

Viewing the CAT infrastructure solely as a regulatory burden is a failure of imagination. It is a system that, by its very design, provides the raw material for a deeper understanding of market mechanics and a firm’s unique position within them. The challenge now is to build an intelligence layer on top of this data foundation. How can the granular, cross-asset class data from CAT be integrated with other data sources ▴ market data, risk analytics, client relationship information ▴ to create a truly holistic view of the business?

The firms that can answer this question will not only navigate the new regulatory landscape with confidence but will also unlock a powerful source of competitive advantage. The system is in place; the opportunity is to harness its potential.

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## 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">
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## 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">
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## 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/question/what-is-the-role-of-an-approved-reporting-mechanism-arm-in-the-mifir-transaction-reporting-protocol/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
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## Reporting Framework

An ARM is a specialized intermediary that validates and submits transaction reports to regulators, enhancing data quality and reducing firm risk. </a><a href="https://prime.greeks.live/area/finra/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
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## 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/listed-options/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
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## Listed Options

Meaning ▴ Listed options represent standardized derivative contracts traded on regulated exchanges, granting the holder the right, but not the obligation, to buy or sell an underlying asset at a predetermined strike price on or before a specified expiration date. </a><a href="https://prime.greeks.live/area/data-capture/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sleek, cream-colored, dome-shaped object with a dark, central, blue-illuminated aperture, resting on a reflective surface against a black background. This represents a cutting-edge Crypto Derivatives OS, facilitating high-fidelity execution for institutional digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-prime-os-high-fidelity-rfq-execution-engine-intelligence-layer.jpg)

## Data Capture

Meaning ▴ Data Capture refers to the precise, systematic acquisition and ingestion of raw, real-time information streams from various market sources into a structured data repository. </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">
![Abstract spheres and a sharp disc depict an Institutional Digital Asset Derivatives ecosystem. A central Principal's Operational Framework interacts with a Liquidity Pool via RFQ Protocol for High-Fidelity Execution](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-framework.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/data-granularity/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A polished blue sphere representing a digital asset derivative rests on a metallic ring, symbolizing market microstructure and RFQ protocols, supported by a foundational beige sphere, an institutional liquidity pool. A smaller blue sphere floats above, denoting atomic settlement or a private quotation within a Principal's Prime RFQ for high-fidelity execution](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-market-microstructure-and-rfq-protocols.jpg)

## Data Granularity

Meaning ▴ Data granularity refers to the precision or fineness of data resolution, specifying the degree of detail at which information is collected, processed, and analyzed within a dataset or system. </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">
![Central teal-lit mechanism with radiating pathways embodies a Prime RFQ for institutional digital asset derivatives. It signifies RFQ protocol processing, liquidity aggregation, and high-fidelity execution for multi-leg spread trades, enabling atomic settlement within market microstructure via quantitative analysis](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-core-for-institutional-digital-asset-rfq-protocol-execution-engine.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/compliance-framework/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A stacked, multi-colored modular system representing an institutional digital asset derivatives platform. The top unit facilitates RFQ protocol initiation and dynamic price discovery](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-engine-15.jpg)

## Compliance Framework

Meaning ▴ A Compliance Framework constitutes a structured set of policies, procedures, and controls engineered to ensure an organization's adherence to relevant laws, regulations, internal rules, and ethical standards. </a><a href="https://prime.greeks.live/area/data-sources/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Abstract geometric structure with sharp angles and translucent planes, symbolizing institutional digital asset derivatives market microstructure. The central point signifies a core RFQ protocol engine, enabling precise price discovery and liquidity aggregation for multi-leg options strategies, crucial for high-fidelity execution and capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/principals-operational-framework-optimizing-institutional-digital-asset-derivatives-rfq-protocol-execution-for-alpha-generation.jpg)

## Data Sources

Meaning ▴ Data Sources represent the foundational informational streams that feed an institutional digital asset derivatives trading and risk management ecosystem. </a><a href="https://prime.greeks.live/area/cat-data/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![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)

## Cat Data

Meaning ▴ CAT Data represents the Consolidated Audit Trail data, a comprehensive, time-sequenced record of all order and trade events across US equity and options markets. </a><a href="https://prime.greeks.live/area/transaction-cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sleek, metallic multi-lens device with glowing blue apertures symbolizes an advanced RFQ protocol engine. Its precision optics enable real-time market microstructure analysis and high-fidelity execution, facilitating automated price discovery and aggregated inquiry within a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-engine-intelligence-layer.jpg)

## Transaction Cost Analysis

Meaning ▴ Transaction Cost Analysis (TCA) is the quantitative methodology for assessing the explicit and implicit costs incurred during the execution of financial trades. </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 modular system with beige and mint green components connected by a central blue cross-shaped element, illustrating an institutional-grade RFQ execution engine. This sophisticated architecture facilitates high-fidelity execution, enabling efficient price discovery for multi-leg spreads and optimizing capital efficiency within a Prime RFQ framework for digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/principal-prime-os-rfq-engine-for-digital-asset-derivatives.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/cat-nms-plan/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Engineered components in beige, blue, and metallic tones form a complex, layered structure. This embodies the intricate market microstructure of institutional digital asset derivatives, illustrating a sophisticated RFQ protocol framework for optimizing price discovery, high-fidelity execution, and managing counterparty risk within multi-leg spreads on a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-protocol-stack-optimization.jpg)

## Cat Nms Plan

Meaning ▴ The Consolidated Audit Trail National Market System Plan, or CAT NMS Plan, establishes a centralized repository for granular order and trade data across U.S. </a><a href="https://prime.greeks.live/area/nms-plan/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Layered abstract forms depict a Principal's Prime RFQ for institutional digital asset derivatives. A textured band signifies robust RFQ protocol and market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/digital-asset-derivatives-rfq-high-fidelity-execution-prime-os-market-microstructure.jpg)

## Nms Plan

Meaning ▴ The NMS Plan, within the context of institutional digital asset derivatives, defines a conceptual framework for structuring market operations to ensure transparency, fairness, and efficient price discovery across distributed ledger technology-based trading venues. </a><a href="https://prime.greeks.live/area/cat-nms/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sophisticated dark-hued institutional-grade digital asset derivatives platform interface, featuring a glowing aperture symbolizing active RFQ price discovery and high-fidelity execution. The integrated intelligence layer facilitates atomic settlement and multi-leg spread processing, optimizing market microstructure for prime brokerage operations and capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/institutional-crypto-derivatives-rfq-engine-intelligence-layer.jpg)

## Cat Nms

Meaning ▴ The Consolidated Audit Trail (CAT) National Market System (NMS) Plan establishes a centralized, comprehensive database designed to track the lifecycle of orders and trades in U.S. </a>

**Tags:** [CAT NMS Plan](https://options.greeks.live/area/cat-nms-plan/), [Listed Options](https://options.greeks.live/area/listed-options/), [Audit Trail](https://options.greeks.live/area/audit-trail/), [Compliance Framework](https://options.greeks.live/area/compliance-framework/), [Broker-Dealer Reporting](https://options.greeks.live/area/broker-dealer-reporting/), [Data Sources](https://options.greeks.live/area/data-sources/)	

## Discover More

- 
### [What Are the Specific CAT Reporting Differences between a Principal and Agency Block Trade?](https://options.greeks.live/question/what-are-the-specific-cat-reporting-differences-between-a-principal-and-agency-block-trade/)
![The abstract visual depicts a sophisticated, transparent execution engine showcasing market microstructure for institutional digital asset derivatives. Its central matching engine facilitates RFQ protocol execution, revealing internal algorithmic trading logic and high-fidelity execution pathways. This metaphor underscores capital efficiency and best execution within a Prime RFQ framework.](https://options.greeks.live/wp-content/uploads/2025/07/principal-rfq-engine-for-institutional-digital-asset-derivatives.jpg)

CAT reporting differs by encoding the firm's role: agency as a client-centric service, principal as a capital-committing act.

- 
### [What Are the Supervisory Responsibilities for Firms Using Third Party Cat Reporting Vendors?](https://options.greeks.live/question/what-are-the-supervisory-responsibilities-for-firms-using-third-party-cat-reporting-vendors/)
![A central glowing core within metallic structures symbolizes an Institutional Grade RFQ engine. This Intelligence Layer enables optimal Price Discovery and High-Fidelity Execution for Digital Asset Derivatives, streamlining Block Trade and Multi-Leg Spread Atomic Settlement.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-engine-microstructure-core.jpg)

A firm's duty is to build and execute a robust supervisory system to verify the accuracy of its vendor's CAT reporting.

- 
### [What Are the Key Differences between an RFQ Audit Trail and Chat Logs?](https://options.greeks.live/question/what-are-the-key-differences-between-an-rfq-audit-trail-and-chat-logs/)
![Modular circuit panels, two with teal traces, converge around a central metallic anchor. This symbolizes core architecture for institutional digital asset derivatives, representing a Principal's Prime RFQ framework, enabling high-fidelity execution and RFQ protocols.](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-protocol-engine-prime-os.jpg)

An RFQ audit trail is the immutable, structured ledger of a trade; a chat log is the unstructured, contextual human dialogue around it.

- 
### [How Does the Consolidated Audit Trail Differentiate between an IOI Message and an Actionable RFQ Response?](https://options.greeks.live/question/how-does-the-consolidated-audit-trail-differentiate-between-an-ioi-message-and-an-actionable-rfq-response/)
![A glowing, intricate blue sphere, representing the Intelligence Layer for Price Discovery and Market Microstructure, rests precisely on robust metallic supports. This visualizes a Prime RFQ enabling High-Fidelity Execution within a deep Liquidity Pool via Algorithmic Trading and RFQ protocols.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-core-intelligence-layer-for-rfq.jpg)

CAT distinguishes IOIs as non-firm inquiries from actionable RFQ responses, which are firm orders triggering reporting.

- 
### [How Does the CAT Balance Regulatory Oversight with Data Privacy Concerns?](https://options.greeks.live/question/how-does-the-cat-balance-regulatory-oversight-with-data-privacy-concerns/)
![A balanced blue semi-sphere rests on a horizontal bar, poised above diagonal rails, reflecting its form below. This symbolizes the precise atomic settlement of a block trade within an RFQ protocol, showcasing high-fidelity execution and capital efficiency in institutional digital asset derivatives markets, managed by a Prime RFQ with minimal slippage.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-microstructure-6.jpg)

The Consolidated Audit Trail balances oversight and privacy by using anonymized customer IDs for routine surveillance and restricting access to personal data to authorized, audited investigations.

- 
### [How Does the CAT Framework Alter the Profitability of Market Making Strategies?](https://options.greeks.live/question/how-does-the-cat-framework-alter-the-profitability-of-market-making-strategies/)
![A sleek, dark metallic surface features a cylindrical module with a luminous blue top, embodying a Prime RFQ control for RFQ protocol initiation. This institutional-grade interface enables high-fidelity execution of digital asset derivatives block trades, ensuring private quotation and atomic settlement.](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-protocol-engine-module-for-high-fidelity-execution-and-liquidity-aggregation.jpg)

The CAT framework alters market-making profitability by translating every quote and order into a direct cost and a permanent data point.

- 
### [How Does the Choice of an RFQ Framework Impact Compliance Reporting Obligations?](https://options.greeks.live/question/how-does-the-choice-of-an-rfq-framework-impact-compliance-reporting-obligations/)
![A precision optical component on an institutional-grade chassis, vital for high-fidelity execution. It supports advanced RFQ protocols, optimizing multi-leg spread trading, rapid price discovery, and mitigating slippage within the Principal's digital asset derivatives.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-optical-component-prime-os.jpg)

The choice of an RFQ framework defines the architecture of a firm's compliance data, directly impacting the integrity of its reporting.

- 
### [How Does the Consolidated Audit Trail Change Latency Arbitrage Strategies?](https://options.greeks.live/question/how-does-the-consolidated-audit-trail-change-latency-arbitrage-strategies/)
![A metallic cylindrical component, suggesting robust Prime RFQ infrastructure, interacts with a luminous teal-blue disc representing a dynamic liquidity pool for digital asset derivatives. A precise golden bar diagonally traverses, symbolizing an RFQ-driven block trade path, enabling high-fidelity execution and atomic settlement within complex market microstructure for institutional grade operations.](https://options.greeks.live/wp-content/uploads/2025/07/precision-execution-protocols-navigating-digital-asset-derivatives-market-microstructure-for-optimal-block-trade-liquidity.jpg)

The Consolidated Audit Trail transforms latency arbitrage by shifting the strategic focus from pure speed to algorithmically defensible execution.

- 
### [What Are the Primary Challenges in Reporting Non-Actionable RFQ Responses to CAT?](https://options.greeks.live/question/what-are-the-primary-challenges-in-reporting-non-actionable-rfq-responses-to-cat/)
![Sleek dark metallic platform, glossy spherical intelligence layer, precise perforations, above curved illuminated element. This symbolizes an institutional RFQ protocol for digital asset derivatives, enabling high-fidelity execution, advanced market microstructure, Prime RFQ powered price discovery, and deep liquidity pool access.](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-digital-asset-derivatives-rfq-protocol-high-fidelity-execution-1.jpg)

Reporting non-actionable RFQs to CAT presents a systemic conflict between bespoke negotiation logic and rigid surveillance data architecture.

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    "@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"
    }
}
```

```json
{
    "@context": "https://schema.org",
    "@type": "FAQPage",
    "mainEntity": [
        {
            "@type": "Question",
            "name": "What Is The Fundamental Difference In Scope?",
            "acceptedAnswer": {
                "@type": "Answer",
                "text": "The fundamental difference in scope between OATS and CAT lies in their jurisdictional and product coverage. OATS was a FINRA-mandated system, and its reach was therefore limited to FINRA member firms and their activities in NASDAQ and OTC equity securities. This created a powerful, yet circumscribed, view of the market. It was an audit trail for a significant portion of the market, but a portion nonetheless. This jurisdictional limitation meant that order flow originating from or routed through non-FINRA member entities, or activity in other asset classes like listed options, was outside its purview. The system was designed to address the regulatory needs of a single SRO, and its architecture reflected this focused mandate."
            }
        },
        {
            "@type": "Question",
            "name": "How Does Data Granularity Differ?",
            "acceptedAnswer": {
                "@type": "Answer",
                "text": "The divergence in data granularity between OATS and CAT is a direct consequence of their differing architectural goals. OATS was designed to provide an audit trail of order events. It captured essential information about the lifecycle of an order: its origination, routing, modification, and execution. While detailed, the data requirements were tailored to FINRA's surveillance needs and focused primarily on the actions of the broker-dealer handling the order. The system was effective at tracking the sequence of events for a given order within its reporting universe."
            }
        }
    ]
}
```


---

**Original URL:** https://options.greeks.live/question/what-are-the-primary-differences-between-oats-and-cat-reporting-for-broker-dealers/
