November 30, 2020

Vanessa Countryman
Secretary
Securities and Exchange Commission
100 F Street NE., Washington, DC 20549

Re: File No. S7-10-20; Amendments to the National Market System Plan Governing the Consolidated Audit Trail to Enhance Data Security

Dear Ms. Countryman:

The Securities Industry and Financial Markets Association (“SIFMA”)1 respectfully submits this letter to the U.S. Securities and Exchange Commission (“SEC” or “Commission”) to comment on the above-referenced proposed amendments (the “Proposal”) to the NMS plan governing the Consolidated Audit Trail (the “CAT NMS Plan” or “Plan”).2 The Proposal is designed to strengthen the security and protections for data in the Consolidated Audit Trail (“CAT”) and to limit the scope of sensitive information required to be collected by the CAT. 3 SIFMA has long supported the development of the CAT and believes that it will provide a critical market infrastructure resource for regulators to track equity and options trading activity across markets. At the same time, SIFMA has long been extremely concerned and vocal about the protection of CAT Data within the CAT System by the self-regulatory organizations (“SROs”) as the developers and operators of the CAT.4 As we have noted, the value of the data within the system is immeasurable and the SROs have the responsibility to protect it along with the associated liability should the data be exposed. Overall, we believe that the Proposal represents a significant step forward by the Commission in holding the CAT to the highest security standards. We applaud the Commission for issuing it and support much of what is included in it. We nonetheless believe that there are certain minor enhancements, discussed below, that the Commission should consider in connection with finalizing the Proposal.