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Goldman Sachs Fined $1.45 Million for CAT Reporting and Trade Accuracy Failures

fined $1,450,000

According to FINRA, Goldman Sachs & Co. LLC was censured and fined $1,450,000 (with $1,355,000 payable to FINRA) for failing to accurately report data to the Consolidated Audit Trail (CAT) and for related trade reporting and supervision failures.

The New York firm inaccurately reported 36.6 billion order events to the CAT Central Repository. Two error types accounted for approximately 36 billion of these events: over 33 billion events were submitted without the required counterparty restriction handling instruction, and over 2.9 billion equity order events were reported with an inaccurate customer displays instruction flag.

Beyond CAT reporting, the firm made over 90 million inaccurate order memoranda, inaccurately reported over 6.8 million trades to a trade reporting facility, overreported over 98,000 trades, and issued over 372,000 inaccurate trade confirmations.

The problems stemmed from a technology update that converted certain principal orders to agency orders. This reconfiguration caused cascading trade reporting violations across multiple systems.

The firm failed to establish a supervisory system reasonably designed to achieve order capacity accuracy. Specifically, the firm had no process to review whether the capacity reflected in its books, records, trade reports, or confirmations was accurate.

The Consolidated Audit Trail is a comprehensive database of all U.S. equity and options transactions, designed to help regulators reconstruct market events and identify manipulation. When firms report inaccurate data to CAT, it undermines this regulatory oversight capability.

The firm has since remediated these issues.

For investors, while these reporting errors may seem like technical back-office matters, accurate trade records are essential for regulatory oversight and for resolving disputes about specific transactions.

Source: FINRA disciplinary actions (PDF)