Creating & Implementing Consolidated Audit Trails

SIFMA provides comments to the self-regulatory organizations (SROs) and the Securities and Exchange Commission (SEC) on  a request for proposal (RFP) relating to the creation and implementation of the consolidated audit trail (CAT) under Rule 613 of the Securities and Exchange Act of 1934 (the Exchange Act).  SIFMA supports the development of a national market system plan (NMS Plan) for the CAT that fully meets the requirements of Rule 613 in an efficient and expeditious manner.  SIFMA believes there are a number of steps that the SROs should take at this stage to improve the process and ensure the best possible outcome including: Defer Issuing an RFP; Provide Transparency and Form the Advisory Committee; Address SRO Conflicts of Interest; Propose Funding Models and Cost Allocation; Determine Governance and Ownership Structure; Establish Single SRO Point of Contact; and Plan for Elimination of Legacy Systems.