If your firm has spent the last few years building out CAT reporting, you know the drill. Order events, timestamps, lifecycle data, all of it has to be captured, validated, and reported without gaps. So when 606 reporting lands on the same desk, it can feel like starting from zero again: a new set of fields, a new validation process, a new report to build.
At Capital Market Solutions, we often ask compliance teams a simple question: if you’re already managing detailed order and routing data for CAT, why treat 606 as a completely separate process?
What Is SEC Rule 606 Reporting?
SEC Rule 606 reporting requires broker-dealers to publish quarterly disclosures detailing how they route customer orders in NMS stocks and listed options. These reports provide greater transparency into where orders are routed and certain financial arrangements between broker-dealers and the venues receiving those orders.
There are two parts to this. Rule 606(a) covers quarterly public reports on order routing practices across all customer orders. Rule 606(b) is different: it covers reports generated in response to a specific customer’s request about how their own orders were routed. One is a standing obligation. The other is triggered on demand.
Either way, the report is only as good as the data behind it. If routing details are incomplete or inconsistent, the report may not accurately reflect the underlying activity, and fixing those issues after the fact eats up time nobody has
CAT and 606: Different Rules, Related Data Challenges
CAT and 606 are not the same requirement wearing different names.
CAT tracks the full lifecycle of an order across the market. 606 is about routing disclosures, including where certain orders were sent and information about relevant financial arrangements with those venues. They exist for different reasons and answer different regulatory questions.
That said, both rules rely on overlapping order and routing data. That overlap matters, and it shows up in a few practical ways:
- Both require accurate order-level detail, often drawn from the same execution and routing systems
- Both depend on clean, well-structured data to hold up under review
- Both involve reconciliation, checking that what’s reported matches what actually happened
- Both benefit from consistent timestamping and order identifiers across datasets
If your firm is already collecting, structuring, and validating this kind of data for CAT, there’s a real opportunity to avoid rebuilding the same groundwork for 606. It’s not about merging the two reports. It’s about not duplicating the effort behind them.
How RSMS for 606 Reporting Can Simplify the Process
This is where RSMS for 606 reporting comes in. Instead of treating 606 as a manual, start-from-scratch process, RSMS brings 606 reporting into the same environment used for CAT compliance. It can work with data from existing sources, while supporting the processing, validation, and consistency checks needed across CAT and 606.
In practice, that means data ingestion from existing sources, automated processing and transformation, and built-in validation checks that catch problems before they become report errors. RSMS also runs consistency checks between CAT and 606 datasets, so discrepancies get flagged early instead of during an exam. Reports can be generated in both PDF and XML formats.
Why This Unified CAT and 606 Data Approach Makes Sense
Using RSMS for CAT alongside RSMS 606 reporting gives firms a more connected approach to managing the data behind both regulatory obligations. Instead of duplicating data preparation and validation wherever possible, firms can create a more consistent workflow across CAT and 606.
The value goes beyond report generation. RSMS also supports cross-regulation surveillance across CAT and 606, helping firms identify inconsistencies in the data used for different regulatory obligations. For compliance teams, that means they can look at the relationship between the datasets rather than reviewing each requirement in isolation.
Make SEC 606 Reporting Less Complicated with RSMS
Your CAT reporting process doesn’t have to sit in its own silo. It can serve as a practical foundation for 606 compliance too, and that shift in thinking is worth more than it might seem at first glance.
RSMS helps broker-dealers take the data they’re already collecting and turn it into audit-ready SEC Rule 606 reports, without duplicating the manual work. Instead of two disconnected processes competing for the same team’s attention, you get a more connected workflow that supports both obligations
Now is a good time to look at what a connected reporting workflow actually changes day to day. The firms that get ahead of this aren’t the ones with the most complicated systems. They’re the ones that stopped duplicating work they’d already done once.
See what a connected workflow with RSMS looks like, and find out how your existing CAT data infrastructure and cross-regulation surveillance can help streamline your 606 reporting process.
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What is the difference between CAT reporting and SEC Rule 606 reporting?
CAT reporting captures detailed order lifecycle events, while SEC Rule 606 focuses on broker-dealers’ disclosures about how customer orders are routed for execution. Although they serve different regulatory purposes, both can rely on overlapping order, routing, execution, timestamps, and identifier data.
Can CAT data be used for SEC Rule 606 reporting?
CAT and SEC Rule 606 have different reporting requirements, so CAT data should not simply be treated as a complete substitute for 606 reporting. However, the order and routing information already maintained for CAT can provide a useful data foundation for preparing and validating 606 disclosures. The CAT NMS Plan specifically states that changes to Rule 606 do not change what is reportable to CAT.
How can broker-dealers simplify SEC Rule 606 reporting?
Broker-dealers can simplify 606 reporting by using existing order and routing data, establishing consistent validation and reconciliation processes, and reducing duplicate data preparation. RSMS brings SEC Rule 606 reporting into the same environment used for CAT compliance, supporting data ingestion, validation, report generation, and oversight.