SIFMA Submits Comments on NMS Plan for the Consolidated Audit Trail

SIFMA submitted comments to the SEC on the proposed National Market System ("NMS") Plan for governing the process of selecting a plan processor and developing a plan for the Consolidated Audit Trail ("CAT"), pursuant to Exchange Act Regulation NMS.

According to the comment letter, SIFMA supports the development of the CAT and believes that it will provide an "invaluable opportunity to enhance the information capture and reporting structure that exists today." SIFMA also supports the basic mechanics of the selection process set forth in the Proposed Plan - in particular, the steps that the SROs have taken to address the conflicts of interest that will arise for SROs that are also bidders to be the plan processor.

However, SIFMA also stated that the selection process must be transparent, and industry representatives should be involved directly in the selection process. Additionally, SIFMA noted that the proposed plan should be amended to provide for the advisory committee required under Rule 613 of Reg. NMS ("Consolidated Audit Trail").

See: SIFMA Comment Letter. Related news: SEC Grants Temporary Rule Exemption Regarding Establishment of a Consolidated Audit Trail (with Lofchie Comment) (December 9, 2013); SIFMA Submits Comments to the SROs and the Exchanges on Selected Consolidated Audit Trail ("CAT") NMS Plan Topics (June 11, 2013); SIFMA Publishes Recommendations for the Creation of a Consolidated Audit Trail (with Barrentine Comment)(March 28, 2013).