Senior Specialist, Consolidated Audit Trail Compliance - Any FINRA Location at FINRA in Rockville, Maryland

Job Description:

The Consolidated Audit Trail (CAT) mandated by the SEC is a comprehensive system allowing regulators to efficiently and accurately track all activity throughout the U.S. markets in National Market System (NMS) securities and unlisted equity securities. CAT is one of the largest data repositories globally, containing a complete record of all equities and options traded in the US. The Senior Specialist is responsible for assisting the Chief Compliance Officer (CCO) and Deputy CCO oversee and manage compliance with all regulatory requirements applicable to FINRA CAT, LLC (FINRA CAT), a subsidiary created by Financial Industry Regulatory Authority, Inc. (FINRA) and selected by Consolidated Audit Trail, LLC to serve as the CAT Plan Processor to build and operate the CAT. The position reports to the Deputy CCO in FINRA CAT’s Office of the CCO. The CCO reports to the CAT NMS Plan Operating Committee; comprised of 20+ SROs and other industry representatives and is responsible for developing and implementing standards and procedures to ensure the effectiveness of the CAT; monitor compliance; and detect, investigate and report instances of non-compliance.

The volume and nature of data collected and stored by CAT further highlights the critical importance of a strong compliance program. While the CCO’s position will reside in FINRA CAT, the CCO has a fiduciary duty to the Consolidated Audit Trail, LLC.

Essential Job Functions:

The Senior Specialist’s primary responsibility is to assist the CCO and Deputy CCO execute their duties and to serve as their designee as warranted. The essential job functions include the following:

• Assist the CCO and Deputy CCO to manage the Plan Processor’s compliance with applicable laws, rules and regulations related to the CAT System, in its capacity as Plan Processor.


• Perform reviews with respect to the matters dealing with compliance issues and report periodically, and on an as needed basis, to the Operating Committee concerning the findings of any such reviews.


• Report in a timely manner to the CCO and Deputy CCO any instances of non- compliance by the Plan Processor with any of the Central Repository’s policies or procedures with respect to information security.


• Assist the CCO and Deputy CCO perform and provide the regular written assessment to the SEC required by Section 6.6 and SEC Rule 613.


• Regularly review the operation of the Central Repository to ensure its continued effectiveness based on market and technological developments. Areas include data accuracy including error rates as required in 613(e)(6), timeliness of reporting, comprehensiveness of data elements, efficiency of regulatory access, system speed, system downtime, system security, and other performance metrics to be determined by the CCO.


• Collaborate with CAT Technology to ensure system effectiveness and resolve any performance issues


• Conduct any relevant review of the Plan Processor or the Central Repository requested by the CCO, Director or the Operating Committee, including directing internal or external auditors, as appropriate, to support any such review.


• Help ensure that the formal policies and procedures information barrier is maintained between FINRA and FINRA CAT.


• Recommend procedures to identify and mitigate any conflicts of interest regarding FINRA CAT’s relationship with FINRA that might arise over time and will annually reevaluate the policies.


• Make appropriate recommendations for enhancements to the nature of the information collected for CAT and the way it is processed.


• Identify and assist the Company in retaining appropriately qualified independent auditors.


• Under the direction of the CCO or the Deputy CCO assist in the implementation of an annual audit plan to audit: all Plan Processor policies, procedures and control structures, policies, procedures and control structures, and real time tools that monitor and address data security issues, for the Plan Processor and the Central Repository


• Assist the CCO or Deputy CCO in assessments of it FINRA CAT is operating consistent with the CAT NMS Plan and its obligations to the Plan Participants.


• Help develop a mechanism to regularly monitor the CAT System for compliance issues.


• Collaborate with and provide support to the Office of the Chief Information Security Officer, as needed.


• Engage with SEC staff and CAT reporters about CAT compliance issues, as needed and in consultation with the CCO, the Senior Director and the Operating Committee.


• Assist in the development and execution of an annual assessment of Business Clock synchronization.


• Support the regular monitoring of the CAT System for compliance by each Participant and each Industry Member per requisite rules and regulations relating to quality and integrity of the CAT and provide the results to the parties with oversight of the respective Participant/Industry Member.


• Assist in the development and implement of a notification and escalation process to resolve and remediate any alleged noncompliance by a Participant or Industry Member.


• Assist in the development and execution of an annual assessment of Business Clock synchronization.


• Assist in other projects and assignments as directed by the CCO or Deputy CCO.

Education/Experience Requirements:

• Bachelor’s degree and a minimum of five (5) years of regulatory or compliance related experience; or an equivalent combination of education and experience


• Advanced degree or law degree a plus


• Understanding of the rules, regulations and guidelines governing the securities industry


• Broad industry knowledge


• Strong verbal and written communication skills


• Excellent judgment and interpersonal skills

Working Conditions:

• Normal office environment. Work outside of business hours and some travel may be required.

Compensation Range for Colorado locations

Annual Salary: $72,400.00 - $129,600.00

#LI-Hybrid

To be considered for this position, please submit an application.

The information provided above has been designed to indicate the general nature and level of work of the position. It is not a comprehensive inventory of all duties, responsibilities and qualifications required.

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Employees may be eligible for a discretionary bonus in addition to base pay. FINRA also provides a variety of benefits including comprehensive health and welfare benefits, life and disability insurance, paid holidays, vacation, personal, and sick leave. FINRA offers immediate participation and vesting in a 401(k) plan with company match. You will also be eligible for participation in an additional FINRA-funded retirement contribution, our tuition reimbursement program and many other benefits. If you would like to contribute to our important mission and work collegially in a professional organization that values intelligence, integrity and initiative, consider a career with FINRA.

Important Information

FINRA’s Code of Conduct imposes restrictions on employees’ investments and requires financial disclosures that are uniquely related to our role as a securities regulator. FINRA employees are required to disclose to FINRA all brokerage accounts that they maintain, and those in which they control trading or have a financial interest (including any trust account of which they are a trustee or beneficiary and all accounts of a spouse, domestic partner or minor child who lives with the employee) and to authorize their broker-dealers to provide FINRA with duplicate statements for all of those accounts. All of those accounts are subject to the Code’s investment and securities account restrictions, and new employees must comply with those investment restrictions—including disposing of any security issued by a company on FINRA’s Prohibited Company List or obtaining a written waiver from their Executive Vice President—by the date they begin employment with FINRA. Employees may only maintain securities accounts that must be disclosed to FINRA at one or more securities firms that provide an electronic feed (e-feed) of data to FINRA, and must move securities accounts from other securities firms to a firm that provides an e-feed within three months of beginning employment.

You can read more about these restrictions here.

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