SIFMA Statement on Settlement on CAT Reporter Agreement

Washington, D.C., May 13, 2020 – SIFMA today issued the following statement from Kenneth E. Bentsen, Jr., SIFMA president and CEO, on the settlement reached between SIFMA and the SROs for the Consolidated Audit Trail (CAT) Reporter Agreement:

“Today, SIFMA and the SROs reached a settlement of the SEC proceeding filed by SIFMA challenging the Consolidated Audit Trail Reporter Agreement.  Under the settlement, the SROs agreed to remove the language from the CAT Reporter Agreement limiting SRO liability for a breach of the CAT database.  The SROs further agreed not to impose any limitation of liability language in the Reporter Agreement without first proposing a rule and going through the formal public notice, comment and approval process with the SEC.  SIFMA has joined the SROs in filing a stipulation of dismissal with the SEC with respect to our Section 19(d) application.  With today’s settlement we have accomplished all that we sought by filing the Section 19(d) application.

“SIFMA’s guiding principle is ‘they who hold the data bear the liability,’ and it was inappropriate and unfair for the SROs to unilaterally impose limits on their liability when they alone hold and control the data inside the CAT, the largest data base to ever be constructed.  While SIFMA supports the goals of the CAT and our members have invested substantial resources toward its implementation, we remain vigilant regarding the risks to sensitive customer information being compiled in one government-mandated database and we will strenuously oppose efforts to shield responsibility for maintaining the security and privacy of such data.”


SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit