Proposed Arbitration Rule
SIFMA Submits Comments to the Consumer Financial Protection Bureau (CFPB) on their proposed rule regarding class action waivers and arbitral records.
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- LettersDec 19, 2025
Prohibition on the Use of Reserve Funds by the Consolidated Audit Trail National Market System Plan
SIFMA submitted a letter to the SEC opposing the proposed amendment to the CAT NMS Plan, which seeks to readopt a vacated funding model. They argue that using reserves built under the invalid model for CAT funding is unlawful and contradicts the court's decision. SIFMA recommends holding reserves in escrow until a new funding path is established.
Details
More Content
- LettersDec 19, 2025
Prohibition on the Use of Reserve Funds by the Consolidated Audit Trail National Market System Plan
SIFMA submitted a letter to the SEC opposing the proposed amendment to the CAT NMS Plan, which seeks to readopt a vacated funding model. They argue that using reserves built under the invalid model for CAT funding is unlawful and contradicts the court's decision. SIFMA recommends holding reserves in escrow until a new funding path is established.