The clock is ticking for broker-dealers as well as equities and options exchange as they have until mid-May to synchronize their business clocks as the next phase of the Consolidated Audit Trail’s rollout.

Firms that have a European presence may find the exercise familiar, according to Maryse Gordon, business development and pre-sales at UnaVista.

“Similarities between regulations like MiFIR reporting or EMIR reporting helps us identify where we see there might be potential issues for firms in complying with the new regulation,” she said.

Broker-dealers also might be tempted to take a tactical approach and leverage their existing OATS reporting infrastructure as much as is possible and then only tack on the necessary changes to meet the new regulations.

However, Gordon suggested firms take a more strategic approach to rationalizing their reporting infrastructure.

“If they can use this as an opportunity cast a wider net across the organization and maybe streamline that reporting process across multiple regulations and jurisdictions, it might help them improve efficiency and effectiveness of managing reporting obligations,”  she said. “I think that this could be one way for firms to consolidate that effort, by looking at it as a more holistic reporting obligation across their organization.”

The new trading reporting method and format will be significantly different from trading reporting under FINRA’s Order Audit Trail System. But exactly how different it will be is hard to say, according to Gordon

“Not until we really have visibility from Thesys as to what their data requirements are going to be can firms really that firms make a valid guess at what the uplift will be for this,” she said. “At the moment, they are anticipating certain things. There are consultants out there providing feedback and insight into what they think might happen. I don’t think anything will be definitively known until we get that visibility from the CAT processor.”

In the meantime, exchanges have until mid-January 2018 before they must start submitting trade data to the CAT.

All, but the smallest SRO members will not be required to provide their trade data to the CAT until January 2019. For the smallest SRO members, the deadline is January 2020.

“That gives the sell-side community an opportunity to see what the pain points are with regards to that first phase,” noted Gordon. “And then, will obviously structure their scope and their timeframe to comply with that regulation when it’s their turn to go live.”