SIFMA provided comments to the SEC on the above-referenced proposed amendment (the “Proposal”) to the National Market System Plan Governing…
The Honorable Allison Herren Lee
U.S. Securities and Exchange Commission
100 F Street NE
Washington, DC 20549
Re: Request for a Temporary Pause Related to Further Development and Implementation of the Final Full Customer & Account Information System Specification for the Consolidated Audit Trail
Dear Acting Chair Lee:
On behalf of its Industry Members,1 the Securities Industry and Financial Markets Association (“SIFMA”)2 respectfully submits this letter to request that the Securities and Exchange Commission (“Commission” or “SEC”) immediately order a temporary pause related to the further development and implementation by FINRA CAT as the CAT NMS Plan Processor and the CAT NMS Plan Participants (“Participants”) of the final full Customer & Account Information System (“CAIS”) technical specification on customer and account reporting to the Consolidated Audit Trail (“CAT”) to allow for an reassessment of whether the personally identifiable information (“PII”) and other customer-related data planned to be reported to and maintained within the CAIS database is necessary or appropriate to fulfill the purpose of the CAT particularly in light of the evolving risk landscape. As you know, the CAT was created to track equity and options trading activity across all of the markets with the goal of facilitating more efficient surveillance of such activity. With this goal in mind, SIFMA member firms have diligently worked to help implement the transactional database of the CAT System, devoting significant time, resources and knowledge to ensure that the development of the database is meeting the implementation milestones set forth set forth in the CAT NMS Implementation Plan established by the self-regulatory organizations (“SROs”) as the Plan Participants.3 SIFMA member firms, however, continue to have serious concerns about the scope of PII data to be reported to and maintained within the CAIS database of the CAT.