The short answer: FINRA CAT has scheduled extended-hours testing with FINRA Trade Reporting Facilities and the exchanges for November 6 and 7, 2026. Firms taking part in the CAT reporting component must submit corresponding linkage-eligible CAT events by 8:00 a.m. ET on November 10, 2026. The CAT Industry Test Environment is expected to open at approximately 10:00 a.m. ET on November 9, and CAT linkage feedback is expected by 9:00 p.m. ET on November 10. Participation is encouraged rather than universally mandated, and FINRA CAT has described this as the only CAT-supported TRF linkage testing opportunity associated with the extended-hours initiative before expanded hours go operational.

The Consolidated Audit Trail is the repository through which self-regulatory organizations and the Securities and Exchange Commission reconstruct market activity. Firms submit order events, trade events, and related data, and the plan processor matches what a firm reports against what the relevant exchange or TRF reports for the same transaction. When those two sides do not reconcile, the result is an unlinked or partially linked event, and reconstruction of the transaction becomes a manual exercise. The November testing weekend exists to exercise that matching process in a part of the trading day that historically did not generate much traffic.

What 23x5 Trading Support Changes for Reporting

The term 23x5 describes a trading week that spans 23 hours a day across five days, rather than the conventional single session with a closing bell and an overnight gap. Under the expanded schedule announced for the FINRA Trade Reporting Facilities, the reporting window runs from Sunday evening through Friday evening, with a scheduled technical pause during the evening hours on weekdays. The practical effect is that a trade can arrive at almost any hour, including hours in which a firm has historically staffed no one and run no batch process.

Reporting that was designed around a narrow session does not automatically stretch. Four areas tend to need attention:

• Timestamps and session attribution. A trade that occurs after midnight now belongs to a trading day and a session determined by the applicable rules and the firm's own configuration, not by the clock on a desk that is empty at that hour.
• Event linkage. Trade events must be reportable and matchable against the TRF or exchange submission for the same execution. Sparse overnight volume makes linkage errors easier to miss by inspection and easier to catch by automated feedback.
• System and reporting infrastructure. Batch windows, file cutoffs, and vendor delivery schedules built for a daytime cycle may not cover activity that occurs at 2:00 a.m. on a Tuesday.
• Reconciliation and validation. Firms that review linkage exceptions on a next-morning basis need to confirm that the review actually covers the full reporting window, including the hours nobody used to work.

The scope of what a specific firm must change depends on its own architecture and reporting chain, so the authoritative source remains the FINRA CAT technical specifications for 23x5 trading support rather than a summary of them. Those specifications are the reference against which a firm should test, and they are updated as the working group releases revisions.

Key Dates and Deadlines

Two details in that table deserve emphasis, because both are easy to misread in a calendar entry. First, the November 9 opening is approximate and is confirmed by the official email announcement, so a submission workflow that depends on the environment being available at a precise minute is a fragile workflow. Second, the November 10 evening delivery is the only scheduled feedback delivery for the November 6 and 7 weekend test data. There is no second review cycle to fall back on.

Note also the compression between two of those lines. Events are due at 8:00 a.m. ET and feedback is expected roughly thirteen hours later. A firm that intends to act on feedback within the week needs people available on November 10 evening and on November 11, not just a ticket in a queue.

How Participating Firms Should Prepare

FINRA CAT's recommended participation sequence is straightforward, and the sequencing itself carries information about where firms usually fall behind:

1. Notify the FINRA CAT Helpdesk of interest in participating in the CAT reporting component. The Helpdesk is reachable at help@finracat.com or (888) 696-3348.
2. Participate in the applicable FINRA TRF and exchange extended-hours testing on November 6 and 7. The CAT component depends on real test activity existing to link against.
3. Submit corresponding linkage-eligible CAT events once the CAT Industry Test Environment opens.
4. Complete submissions before 8:00 a.m. ET on November 10.
5. Review linkage results and feedback through standard CAT Industry Test processing, and record what did not link and why.

One clarification worth stating plainly: this announcement encourages participation. It should not be described internally, or to a board or banking partner, as a new universal testing requirement imposed on every broker-dealer. Whether a particular firm should take part is a judgment about its own reporting chain, its vendors, and the size of the change it is making. A firm with no extended-hours activity, no relevant system change, and clean linkage history has a different calculus from a firm rewriting its overnight reporting.

How CAT Trade Event Linkage Actually Works

Linkage is a matching exercise. An eligible CAT trade event reported by a firm is compared against the eligible trade submitted to the FINRA TRF or the exchange test environment for the same execution. Where the identifiers, the execution details, and the reported attributes line up, the event links. Where they do not, the event remains unlinked or requires manual resolution.

What makes the test valuable is not the pass rate. It is the diagnostic detail in the failures. Three categories tend to account for most linkage problems in a new trading window:

• Identifier mismatches between what the firm reports and what the venue reports, often introduced by a translation layer in a middle office or a vendor feed rather than by the order management system itself.
• Timing and sequencing errors, where an event is reported with a timestamp or sequence that does not reconstruct the way the venue recorded the execution, which becomes more likely when a firm's internal clock handling assumes a single daily session.
• Missing or duplicated events, where a submission path fails silently overnight or retries create a second copy of an event that is then difficult to pair.

General operational practice, such as reconciling before submission and preserving the raw venue files used for comparison, supports this work, but it is not the same thing as a documented CAT processing requirement. Firms should keep the two separate in their procedures so that a review can distinguish a rule from a good habit.

Why This Testing Opportunity Matters

FINRA CAT has identified this as the only CAT-supported TRF linkage testing opportunity associated with the FINRA TRF extended-hours initiative before the expanded hours reach production. That single fact drives most of the practical reasoning about whether to participate.

Linkage defects are not evenly distributed across a trading week. They cluster in the edges: the first trades of a session, the last trades before a pause, executions that cross a date boundary, and activity that arrives when no one is watching a screen. A firm that waits for production to discover how its reporting behaves at 9:15 p.m. on a Sunday is discovering it with live regulatory obligations attached and no controlled environment in which to isolate the cause.

The TRF operating-hour expansion itself has been announced by the FINRA and Nasdaq trade reporting facilities for December 6, 2026. Firms should confirm that date and its exceptions against the TRF notices rather than a summary, and should treat successful November testing as evidence about readiness, not as a certification of it. Testing produces information. It does not produce a favorable examination outcome, and no test result should be described as if it did.

Compliance and Operational Readiness Checklist

The following are recommended preparation activities, not newly mandated requirements.

• Confirm whether the firm is participating and who owns the decision, including whether a vendor or clearing arrangement means someone else is doing the submission.
• Review the applicable CAT technical specifications for 23x5 trading support, including any revisions issued since the last review.
• Coordinate reporting, technology, and operations so that one person owns the submission and one person owns the comparison against venue output.
• Prepare linkage-eligible CAT event submissions in advance, including a defined data set rather than an improvised export on the morning of November 10.
• Monitor the official test environment opening announcement and build slack into the plan for an approximate start time.
• Validate feedback and document identified issues, including the root cause and the change required, not only the symptom.
• Establish escalation for reporting problems that the test surfaces and no one can resolve before the submission deadline, including a named contact at the vendor and at the Helpdesk.

CAT Reporting Is Not AML Transaction Monitoring

These are separate frameworks with separate purposes, and conflating them produces procedures that satisfy neither. CAT reporting is a securities market reconstruction obligation: it exists so that regulators can rebuild the order and execution lifecycle across venues. Bank Secrecy Act and anti-money laundering obligations are a different body of requirements concerned with customer risk, suspicious activity, and financial crime reporting.

Accurate transaction records can support broader compliance governance, because a firm that cannot reconstruct its own activity has a weak foundation for any surveillance program built on top of it. But CAT reporting does not replace AML transaction monitoring. It does not generate suspicious activity reporting, and it does not satisfy a customer due diligence obligation. Nothing in the November testing announcement should be read as creating an AML requirement, and that point is worth making to anyone in the organization who treats regulatory reporting as a single bucket.

Where the two do meet is in control design. Both depend on data integrity, both degrade when ownership is ambiguous, and both are examined through documentation of what was actually reviewed. Our analysis of the intersection of OFAC sanctions and AML obligations addresses the same distinction in the sanctions context.

What This Means for Financial Services Compliance Teams

Changes in reporting infrastructure rarely stay inside the technology function. A shift in when a firm can report changes who must be available, what a supervisor must review, and what a procedure must say. Three consequences follow.

First, policy language that assumes a closing bell should be read literally and corrected if it no longer describes the business. Second, role descriptions and coverage schedules should reflect the hours in which activity can now occur, including the evening pause and the weekend boundary. Third, documentation should capture the decisions made during the transition, because a gap described in a dated memo is an issue under management, while the same gap discovered by an examiner is a finding.

The coordination point is the one most often missed. Reporting teams, operations, and technology each hold a piece of the picture, and a test weekend compresses the time available to reconcile those pieces. Naming a single accountable owner for the November cycle, with authority to convene all three, is a low-cost control that prevents the most common failure mode: three groups each believing someone else submitted.

Where Soflo Consulting Fits

To be direct about scope: Soflo Consulting provides AML/BSA compliance services, including risk assessments, program development, policy and procedure support, training, completion tracking, and independent review guidance. We do not provide FINRA CAT reporting implementation, trade linkage testing, or technical integration services for CAT submissions, and nothing in this article should be read as an offer to do so.

What we do help with sits adjacent to this work. Firms that carry both securities and BSA obligations often find that their change management, their documentation habits, and their training records are the same weak points in both programs. A BSA risk assessment and a documented AML compliance checklist review frequently surface governance issues that have nothing to do with AML specifically: unclear ownership, undated procedures, and controls that exist on paper only.

Soflo Consulting is not approved, endorsed by, or affiliated with FINRA, the SEC, or the CAT plan processor, and nothing here constitutes a statement of regulatory position on their behalf.

For the November test itself, the Helpdesk is the right channel: help@finracat.com or (888) 696-3348.

Disclaimer: This article is provided for general informational and educational purposes only and does not constitute legal, regulatory, or technical advice. Testing dates, expected environment availability, submission deadlines, and feedback timing are as described in the FINRA CAT industry communication and remain subject to change by the plan processor. Participation in the described testing is encouraged and is not presented here as a universal requirement. Firms should verify all specifications, dates, and obligations against official FINRA CAT documentation and consult qualified counsel or their own technology providers regarding specific circumstances.