On April 26, ION Markets marked a significant Consolidated Audit Trail milestone: the Phase 2c go-live. Although official FINRA CAT support for test file submission and evaluation began in late January, ION Markets began phase 2c preparations in early 2020. While the CAT project continues and there is still much work to be done, preliminary FINRA record ingestion and linkage error statistics, as well as positive customer feedback, indicate that the 2c go-live was a resounding success.
In early 2020, teams at ION Markets initiated analysis of the FINRA CAT 2c specification updates, to identify all requirements relevant to our customers. An extensive library of changes was captured, ranging from minor to complex workflow and reporting scenarios (representative orders and fulfilment linkages). The wide range of applications, front-office businesses, and trading workflows supported in the front office platforms (institutional trading, retail market making, program trading, US equity options, global non-member trading, latency sensitive, etc.) made these requirements a monumental challenge.
Through monthly development build, quality assurance testing, and software release cycles, the CAT 2c functionality was incrementally added to a very large number of customer production systems. After a huge lift by ION Markets’ technical and client software delivery teams, 95% of the 2c changes were fully delivered to customer systems via component upgrades by late January 2021, coinciding with the opening of FINRA CAT’s phase 2c testing facility.
Although it felt great to have so much of the 2c work complete, the short 3-month testing window provided by FINRA stoked anxiety…after all, the 2c go-live was approaching rapidly and no one had submitted a test file yet. Fortunately, multiple customers utilized the new “test run” functionality to create and submit 2c formatted test files using production events, configurations, and static data. This early testing helped identify several minor issues that were addressed prior to the 2c go-live.
After an additional upgrade cycle completion in mid-April, and an automated production migration to the 2c reporting format on April 25, all our clients were ready for the 2c go-live.
Hats off to the entire ION Markets team – ranging from business analysis, development, platform delivery, to technical account management and support.
We join the industry in preparations for the next phase – CAT 2d, going live in mid-December, and its (literally) complex reporting scenarios.
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