SIFMA provides comments to the Development Advisory Group (“DAG”) for the Consolidated Audit Trail (CAT). SIFMA has specific suggestions for priority areas that the DAG should address during 2014.

SIFMA believes that the DAG should refocus its efforts going forward to substantively address the major policy issues surrounding the development of the CAT. With the Self-Regulatory Organizations’ (SROs) selection process for the CAT processor having been approved by the Securities and Exchange Commission (SEC), and with the final processor selection expected to occur during 2014, the broader policy issues are now more timely than the detailed analysis of granular operational issues.

In this regard, SIFMA suggests that the DAG focus on four primary issues:

• Elimination of Systems and Rules; 
• Equitable Cost and Funding; 
• Industry Integration in Governance; and 
• Transparency in the Bidding and Selection Process.