If your firm is already managing CAT reporting, you may have wondered whether all that order and routing information can do more than satisfy CAT requirements. It is a fair question. After all, CAT captures a detailed picture of an order’s journey, from the time it is received through routing, modification, cancellation, and execution. So why build a completely separate process for Rule 606?
The answer is that CAT and 606 are closely related, but they are not the same thing. The challenge is not simply having the information. It is processing that information correctly for the 606 reporting requirement.
This is where RSMS for 606 reporting can make a difference.
CAT and Rule 606 both involve order activity, routing, and execution information, but they serve different regulatory purposes.
CAT is designed to provide regulators with a detailed record of order activity across the lifecycle of a trade. Rule 606 focuses on how customer orders are routed and handled and requires reporting based on specific categories and requirements. So, while there is meaningful overlap, CAT information should not simply be treated as a completed 606 report. There is processing involved. The relevant information needs to be organized, classified, validated, and prepared according to the 606 reporting requirements. That is where a purpose built 606 reporting solution becomes important. The goal is not to make CAT and 606 identical. It is to make the relationship between them easier to manage.
When evaluating a 606 reporting platform, report generation should only be one part of the conversation.
Look at what happens before and after the report is produced. A useful platform should help with data preparation and validation, provide visibility into reporting workflows, support consistency checks, and make it easier for compliance teams to investigate potential issues.
Cross regulatory capabilities are also worth considering. If CAT and 606 information can be reviewed together, firms have a better opportunity to identify inconsistencies that may not be obvious when each reporting obligation is handled separately. These capabilities can turn regulatory reporting from a largely output focused exercise into a more controlled data and compliance process.
RSMS brings Rule 606 reporting into the same regulatory reporting environment used to manage related CAT compliance workflows. Rather than adding another disconnected reporting process, RSMS provides a structured workflow for preparing and managing 606 reporting. The platform supports the data processing, standardization, transformation, and validation required before information reaches the reporting stage. This gives compliance teams greater visibility into the process behind the report, not just the final result.
A report is only one part of the compliance process. Teams also need visibility into the information and controls behind it, particularly when they need to review or investigate an issue. RSMS brings that visibility into the reporting workflow rather than treating the final report as the end of the process.
Looking at each regulatory dataset independently can make it difficult to spot inconsistencies. A record may look correct when reviewed within one reporting process, but a comparison with related information can reveal something that needs attention.
For example, a routing classification may differ. Information expected in one dataset may not appear as expected in another. A pattern in order activity may also warrant further review. RSMS supports Cross Reg 606 & CAT Surveillance to give compliance teams a way to identify these types of inconsistencies across regulatory reporting workflows.
Instead of looking only at whether a 606 report was produced, compliance teams can also ask, “Does the information supporting that report remain consistent with the related CAT information?”
Insider Update: At Capital Market Solutions, we’re taking this a step further. Soon, we will begin publishing SEC 606 reports on our official website, helping firms turn regulatory transparency into a meaningful opportunity to showcase their approach to execution and build trust with clients.
Rule 606 reporting is ultimately about more than producing the required information. It is about having confidence in the data, the process, and the controls behind the final report. When compliance teams have to work across disconnected processes, even a straightforward reporting cycle can become difficult to manage and review.
RSMS helps bring that structure into the 606 reporting workflow, giving broker dealers greater visibility into the information behind their reports and the processes used to prepare them. With a more connected approach, compliance teams can spend less time managing reporting complexity and more time focusing on accuracy, oversight, and regulatory obligations.
Ready to simplify your Rule 606 reporting workflow? See how RSMS can help your compliance team improve visibility, consistency, and control.
SEC Rule 606 reporting requires broker-dealers to disclose information about the routing of customer orders according to applicable reporting requirements. A reliable SEC Rule 606 reporting solution helps organize and validate relevant data for accurate, consistent reporting.
CAT data contains order lifecycle and routing information that may support SEC Rule 606 reporting. However, CAT and Rule 606 have different regulatory requirements, so the relevant data must be classified, transformed, and validated before it can be used for Rule 606 reports.
An SEC Rule 606 reporting platform such as RSMS helps streamline data processing, validation, and reporting workflows. It also supports cross-regulatory CAT and Rule 606 surveillance, helping compliance teams identify inconsistencies and improve visibility into reporting processes.