White Papers

Economic Analysis of Proposed Amendment to National Market System Plan Governing the Consolidated Audit Trail

Summary

SIFMA submitted the following White Paper to the SEC prepared by Professor Craig M. Lewis entitled “Economic Analysis of Proposed Amendment to National Market System Plan Governing the Consolidated Audit Trail.” This supplements SIFMA’s January 27, 2021 comment letter on the SRO proposal to add a limitation of liability provision to the CAT Reporter Agreement.

As set forth in the White Paper, Professor Lewis disagrees with the Charles River Associates report accompanying the proposed amendment and concludes that the proposed amendment, if adopted, would result in a reduction in investor welfare.

See also: Press Release – SIFMA Cautions Liability Provisions Under CAT NMS Plan Will Harm Investors (February 25, 2021)

PDF

Submitted To

SEC

Submitted By

SIFMA

Date

19

February

2021

Excerpt

February 19, 2021

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

Re: File No. 4-698; Joint Industry Plan; Notice of Filing of Amendment to the National Market System Plan Governing the Consolidated Audit Trail by the Plan Participants—Comment Letter of the Securities Industry and Financial Markets Association

Dear Ms. Countryman:

On behalf of Securities Industry and Financial Markets Association (“SIFMA”)1 and as referenced in our comment letter dated January 27, 2021, enclosed is a White Paper prepared by Professor Craig M. Lewis entitled “Economic Analysis of Proposed Amendment to National Market System Plan Governing the Consolidated Audit Trail.” As set forth in the White Paper, Professor Lewis disagrees with the Charles River Associates report accompanying the proposed amendment and concludes that the proposed amendment, if adopted, would result in a reduction in investor welfare.