New FINRA Account Holder Type Consistency Interactive Report Card

On Monday, November 17^th, 2025, FINRA unveiled an interactive report card related to Account Holder Type values reported to the Consolidated Audit Trail (“CAT”). This confirms that FINRA is closely monitoring integrity and consistency of CAT transactional data. The new report card tracks the two essential elements shown below, evaluating the accuracy and consistency of the relationship between these values.

• Firm Designated ID (“FDID”) – The unique identifier for each trading account submitted to CAT.
• Account Holder Type (“AHT”) – The value submitted to CAT reflecting the beneficial owner of the account or “FDID” submitted to CAT.

Reports are run on T+1 and will display instances of where the AHT value differs from another AHT value submitted with the same FDID within the last submission file.

The AHT field has eight allowable reporting values to identify the beneficial owner of a submitted FDID. However, FINRA will group the values of O, P, V, and X and therefore will not identify inconsistencies within those range values.

Only the following reporting events are subject to this enhanced report card review.

 This omits other reporting events which contain AHT.

• All Quote Events (“MENQ,” “MEQR,” “MOQR” and “MLQR”)
• Trade Events (“MEOT,” MEOTS,” “MOOT,” and “MOOTS”)
• Fulfillment Events (“MEOF,” “MEOFS,” “MOOF,” and “MOOFS”)

Although this new interactive report card is helpful to industry members, caution should be taken when incorporating this data into any reasonable surveillance program. The following aspects of this report should be considered.

1. AHT is a critical reporting value in CAT transactional submission that positively identifies the beneficial owner of each account.
2. The new report card shows daily consistency results and will not identify inconsistencies across multiple business day submissions.
3. Beware of false positives and inaccurate non-compliance rates. If an industry member has a more robust surveillance system that preemptively identifies previous inconsistencies that have already been repaired, this new report will still show those historical exceptions.
4. Should industry members further expand their review of AHT consistency to include multi-day reporting, additional reporting events that contain AHT values, as well as the consideration of inconsistencies in grouped reporting values of O, P, V, and X?
5. Are there additional AHT validations that can enhance an industry member’s surveillance of CAT and CAIS reporting? For example, should AHT be compared to any report CAIS data values?
6. Compliance preparedness. It should be obvious that if FINRA is making a significant effort to provide this data to industry members, the regulatory agency has an expectation of how the data should be used and is potentially insightful to future exam findings.

How Compliance Risk Concepts (CRC) Can Help

As FINRA continues to enhance CAT and CAIS oversight, firms should expect growing scrutiny over data integrity, account-level consistency, and the effectiveness of supervisory controls. CRC supports industry members in building CAT/CAIS programs that are accurate, defensible, and examination-ready.

Our team assists firms by providing:

• End-to-End Program Reviews
  Assessment of reporting workflows, governance structures, AHT/FDID mapping logic, reconciliation processes, and escalation procedures to identify gaps and strengthen controls.
• Policy, Procedure, and Surveillance Enhancements
  Development or refresh of WSPs, CAIS governance documents, exception-management protocols, and AHT consistency checks—including considerations beyond the scope of the new report card.
• Data Quality and Reconciliation Support
  Assistance with validating FDID and AHT assignments, remediating inconsistencies, reviewing vendor outputs, and implementing multi-day or multi-event surveillance where appropriate.
• Vendor and Technology Oversight
  Evaluation of reporting vendors, service bureaus, and surveillance platforms with an emphasis on control testing, SLA expectations, and data-handling requirements.
• Training and Ongoing Advisory Support
  Practical training for compliance, operations, and technology teams, as well as ongoing advisory services to help firms stay ahead of regulatory updates and anticipated examination themes.

Whether your firm is evaluating its AHT consistency processes, strengthening its CAT/CAIS governance framework, or preparing for an upcoming FINRA exam, CRC brings regulatory depth and hands-on experience to help you operate with confidence.

If you’d like support reviewing or enhancing your CAT/CAIS reporting program, our team is ready to help.

Tear Sheets for CAT/CAIS

Author:

Ralph Magee, the CRC Oyster CAT CAIS SME