The NMS Plan for a CAT System
SIFMA provided comments to the Securities and Exchange Commission (SEC) on the National Market System (NMS) Plan for developing a Consolidated Audit Trail (CAT). SIFMA members have repeatedly supported the development of the CAT given its potential to enhance the quality and completeness of data provided to regulators and promote fair and equitable markets. However, SIFMA’s comment letter raises substantial concerns with the CAT NMS Plan as it has been proposed, and we believe those issues must be resolved before the SEC approves the NMS Plan.
Most notably, the CAT Plan does not offer concrete steps for the elimination of existing systems that will be obviously duplicative of the CAT – such as FINRA’s OATS system – and instead would give the SROs several years to conduct an analysis before being required to eliminate redundant systems. In addition, the CAT NMS Plan proposes to impose the vast majority of CAT-related costs to broker-dealers without providing any detailed analysis or justification.
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