National Market System Plan for the CAT

SIFMA provides comments to the Securities and Exchange Commission (SEC) on the proposed National Market System Plan governing the process of selecting a plan processor and developing a plan for the Consolidated Audit Trail (CAT) pursuant to Rule 613 of Regulation NMS under the Securities and Exchange Act of 1934, File No. 4-668.

SIFMA continues to support the development of the CAT, and believes that the CAT will provide an invaluable opportunity to enhance the information capture and reporting structure that exists today. Because the CAT will be a critical aspect of market infrastructure, it is imperative that the process through which the CAT is developed and implemented be open and transparent and include the integrated involvement and meaningful participation of representatives of the broker-dealer community.

SIFMA supports the basic mechanics of the selection process set forth in the Proposed Plan, in particular the steps the self-regulatory organizations (SROs) have taken to address the conflicts of interest that will arise for SROs that also are bidders to be the plan processor. However, SIFMA believes the selection process must be transparent as it is carried out, and that industry representatives should be directly involved in the selection process.