Trade & Regulatory Reporting
Institutional, retail and clearing broker-dealers turn to McGuireWoods for end-to-end counsel on trade and regulatory reporting compliance, investigations and enforcement exposure. Drawing on experience inside the SEC and FINRA, our team combines deep technical understanding with practical insight into how regulators analyze trading data, order flow and reporting exceptions.
Our team includes several former FINRA senior officials, including the former head of market regulation enforcement, a chief counsel and a director in that organization, as well as a former trading and market making surveillance examiner. This inside perspective enables us to anticipate examiner expectations and to guide clients through high-stakes reviews, sweeps and enforcement inquiries.
Trade Reporting Counseling and Enforcement
Our team advises broker-dealers, trading firms and alternative trading systems on the full spectrum of trade reporting obligations under Regulation NMS Rules 605, 606 and 611, and FINRA Rules 6110, 6282, 6380A/B, 6622, 6730 (TRACE) and 8211/8212 (Electronic Blue Sheets). We represent clients in SEC and FINRA enforcement investigations involving late, inaccurate or unreported transactions, supervisory control deficiencies and order-routing disclosure issues, as well as in parallel examinations and sweeps. In addition to defending enforcement actions, we provide ongoing counseling on reporting architecture, data governance and supervisory frameworks to mitigate future risk. Drawing on experience from former FINRA Market Regulation staff, our lawyers combine regulatory insight with technical fluency to help clients assess reporting controls, implement remediation and engage credibly with regulators when issues arise.
Consolidated Audit Trail (CAT) Counseling and Enforcement
A cornerstone of our practice, CAT compliance and enforcement defense helps clients manage the complex operational, data integrity and supervisory challenges associated with CAT reporting. CAT requires national securities exchanges and U.S. broker-dealers to report lifecycle events for transactions in NMS equities, listed options and OTC equity securities, including orders, routes, executions and allocations, as well as customer and account information (CAIS).
With the SEC, FINRA and all SROs now able to analyze trading across trading venues, products, customers, third parties with discretionary authority over customer accounts and broker-dealers, firms face heightened exposure to supervisory and data-governance findings. McGuireWoods’ CAT team provides compliance, legal and strategic support, including:
Our integrated team combines regulatory insight, data-governance experience and enforcement defense capabilities to help clients identify issues early and achieve regulator confidence through transparency and corrective action.
Our lawyers are recognized leaders in counseling broker-dealers and market participants on trade reporting, Consolidated Audit Trail (CAT) and other regulatory reporting compliance issues — leveraging decades of government and private practice experience to help clients navigate regulatory nuances and achieve favorable resolutions in this space.