Judy McDonald

CAT Reporting:

From inception, full implementation of all phases of CAT Reporting. Provide daily CAT reporting for two Tier-1 BDs achieving better-than peer error rates. Average daily messages reported in 2025: 15 Billion. (Maybe sketch out history of increase)

Iterative improvements on performance

18BBO project.

Delivered on time, for business opportunity.

Remember DNA and CAS changes in addition to EOT, TORQ, MDF and CT (EFC, CAT, DAT, NDS and changes to existing reports) assumption validaton

Reconciliation between BNR and CAT:

In 2025: increase coverage from 1% to 99% of CAT records. Developed tool to facilitate comparing BD to Exchange reported values, based on sophisticated sampling.

In 2024: devised smart sampling technique to provide meaningful coverage based on 1% sample.

Improving BNR and CAT reporting quality for nuanced special handling instructions, through exchange protocol payload extraction. Cross-team effort (6 teams)

Expanding streamlined pipeline

Stability during 30%-40% increase in message volume Oct – Dec.

Improved initial data capture, operational support, and linkage feedback analysis for BNR in high-frequency trading systems.

Devised big-data strategies to correct 30 historical reports, enhancing accuracy and compliance.

Responses to regulatory inquiry, including BNR to CAT data pulls.

CAIS Reporting

From inception, full implementation of all phases of CAT Reporting. Provide daily CAT reporting for two Tier-1 BDs achieving better-than peer error rates.

Reconciliation between BNR and CAT: 99% coverage

Bona-Fide Market Making Project

Proactively preparing for regulatory scrutiny: collaborated with business, compliance and technology to prepare the firm for new CAT reporting requirement, improve data capture, review classifications of market making strategies and migrate to real-time updates of locate share reserves, establish robust self-surveillance, including dramatic improvements to quote-width report.

Exchange Protocol Payload Extraction Project

Transition to a more automated, efficient, maintainable, and robust source of special handling instructions, augmenting existing data pipelines for BNR and CAT reporting.

Led cross-team effort (6 teams) covering over 40 exchange protocols.

Extensive exchange specification analysis, mapping to CAT representation, manual validation with exchange reporting, supported by sampling technique.

Reg NMS 2.0 Project:

Round lot definition changes (Nov ‘25), BOLO changes (May ‘26)

Led cross-team effort to educate front-office and development teams, identify necessary changes and adopt changes.

Fractional Share Project: Feb ‘25

Led cross-team effort to educate front-office and development teams, identify necessary changes and adopt changes.

Electronic communication (eComm) Project

Proactively addressing regulatory scrutiny

Global, functional support for retention, supervision, legal/regulatory discovery and holds, personal archive.

Created multi-year plan to migrate all functions to new provider, mitigating 3 significant issues with legacy and new vendor. 55TB of historical data migrated.

Implementation of tiered retention policy for all eComm archives.

Extensive work with global teams on communication and mechanics of changes.

SEA 15c3-2 (the Market Access Rule) Program

From inception, created MAR program: coaching front-office developers on risk controls and implementation, annual audits (current 32 system audits, quarterly analysis on risk control limits, CEO certifications.

Most recently: targeted effort to reduce capital and credit limits, 19% in 2025. And reduce unnecessary order routing through an affiliate BD.

Technology Governance:

Established guidelines and protocols for the software development lifecycle for algorithmic trading development and middle- and back-office development.

Established guidelines for technology operations from monitoring, alerting, incident response to after-incident reviews.

Established internal audits supporting critical functions.

Successfully responded to regulatory exams on the topics.

Enterprise Risk:

Established risk framework and risk taxonomy

Established internal audits supporting critical functions: risk control audits, trade recon audits, SDLC audits, 3rd party trading tool audits, information barrier audits, disaster recovery audits.

Led after incident reviews for promoting and tracking remediation and edification of aligned teams.

Led reviews of industry incidents or regulatory findings to ask “could it happen here?”

Successfully responded to regulatory exams on the topics.

Innovation:

Succesfully embracing with a magnification on impact using AI in all stages of the software development lifecycle. ChatGPT and custom GPTs for business and technical analysis, data visualization. Co-pilot, cursor and Claude for code generation and code assistance, unit test case generation. Attacking projects impossible without AI.

Embraced Big Data tools to support processing 18 Billion messages daily, across multiple data pipelines

Complete re-tooling of the team’s skills.

Initiated using quantitative analysis for compliance projects: risk control limit analysis, credit and capital limit analysis, internal equity price reference feed.

Ran POC on use of Databricks/Spark in the Cloud.

Promoted Agile and Kan Ban software development methodologies, “just right” project management.

People leadership:

Team, Enterprise efforts, Technology Summits

Currently leading a team of 39 with 4 team leads. For past 20 plus years, have lead various teams, 28 – 35 people with 4 – 6 team leads.

Mentor: repeatedly complimented for mentorship within and outside of team.

Creative resourcing: because of significant resource shortages during COVID, established relationships three technology contracting firms and successfully drove projects with remote resource augmentation. Novel to SIG and continues today.

Compliance Technology Team satisfies the 4 Pillars of Broker Dealer Requirements:

Capture and quarriable books and records: multi-year evolution to golden source repositories, faster adoption of new markets, migrating to big data tools to better support volumes and special handling instructions. Major improvements to query tool performance and coverage.

Self-Surveillance:

Over 100 real time alerts. Recent highlights: expansion to Canadian trading support, improvements to trade halt monitoring

Real time monitoring on Futures and Options positions, currency trading counterparty credit monitoring

Over 140 T+1 reports. Recent highlights: sophisticated side-marking analysis report, quote width reports, locate shares validation

Regulatory Reporting: CAT, OCEND, Futures Audit Trail, 13F, large trader, 605 and 606 (through vendor), etc.

Responses Examinations and inquiry

Providing Training to Technology Teams:

Developed and delivered training: general regulatory requirements, the Market Access Rule, the Order Protection Rule, FINRA Algo Developer Registration, role of compliance.

Asset classes: equities, ETFs, options, futures, digital assets, currency, FX swap dealer trading, fixed income (bonds, interest rates), prediction markets

Trading Locations: US, Canada, Brazil, Mexico

Main Technologies Used by Teams: Hive, PySpark, YARN, Java, C#, C++, PL/SQL

VAST, GPU-based RAPIDS Spark API,

Grafana, Qlik

Perforce, GitLab, Teamcity, Octopus Deploy, Confluence, Jira, JSM

Special Projects:

· Led Risk Summit 2016

· Led Big Data Track at SIG Technology Summit 2012

· Led Compliance Track at SIG Technology Summit 2010

· To streamline and improve accuracy, created blueprint for trading on a new exchange: from reference data to legal contracts: cross-team efforts across multiple technology teams

Engaged in industry advocacy efforts.

CAT: won exemption for BD reporting of option quotes, won eventual exemption of verbal quotes for BD reporting, significant influence on industry member specifications, FAQs and scenarios, significant influence approach to clock synchronization surveillance, input into data security, Large Trader ID reporting and Customer Account Information.

Industry Speaking Engagements

· Testimony to Senate Banking Committee on Oversight of Status of the Consolidated Audit Trail Oct 2019

o Topics included data security, verbal and manual quotes, fees, SEC proposal on financial accountability

· Panelist on SIFMA Single Stock Circuit Breaker Panel June 2010

· Panelist on 10 different panel discussions, moderator on 2 panels on CAT from May 2013 – May 2021

Topics covered: how to prepare in advance of specifications, differences between CAT and OATS, reference data, symbology, how FAQs are created, FDIDs, industry involvement with creating specifications, detailed specification topics, FINRACAT as the new processor, account information reporting, PII, milestones and timing, retirement of other reporting systems, reporting obligation impact on trading workflows, fees

Industry Groups

· Active member of SIFMA CAT Steering Committee: June 2014 – Dec 2016

· Active member of FIF CAT Sterring Committee: June 2014 – Dec 2016

· Active Member of CAT Development Advisory Group: May 2014 – Jan 2017

· Chair of CAT NMS LLC Advisory Committee Feb 2018 – Aug 2023, member since inception Feb 2017

· FIF Advisory Committee: 1Q2020 – 1Q2026