My Crypto Lawyer Sec Speeches Cryptocurrency Statement on Order Approving CAT Revised Funding Model

Sept. 6, 2023

Over ten years ago, the Commission adopted Rule 613 requiring the creation of a consolidated audit trail, or CAT.

The goal was to improve the Commission’s oversight of our capital markets through consolidated tracking of an order from inception to execution pursuant to a new National Market System (NMS) Plan for the CAT.

Although the CAT has not yet been fully implemented, the Commission is already benefiting from CAT data, by informing rulemaking and facilitating analysis of certain market trends – such as payment for order flow and execution quality in common stocks and ETFs.

Today’s proposal will amend the CAT NMS Plan to implement a revised fee schedule for CAT fees. This amendment is another step towards final completion of the implementation of the CAT.

I support today’s order but with reservations. It is my hope that all stakeholders will work constructively and collaboratively on achieving full implementation of the CAT NMS Plan. The faster the CAT is completed the sooner investors in our markets can realize the full benefits from the strengthened market oversight it is designed to facilitate.

I would like to thank the staff for their hard work on this order and their ongoing efforts to achieve a successful implementation of the CAT.


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