FINRA Proposes CAT Fee Dispute Resolution Procedures

FINRA filed a proposed rule change with the SEC that would implement resolution procedures for disputes that arise in relation to the fees assessed to FINRA members in connection with the Consolidated Audit Trail ("CAT").

New FINRA Rule 6898 concerns the "Fee Dispute Resolution Procedures" adopted by the operating company of the CAT plan. The CAT plan itself establishes guidelines for various aspects of fee dispute proceedings, including (i) providing each member with an opportunity for a review and hearing with respect to the disputed fees, (ii) time limitations for requesting a hearing, (iii) the conduct of administrative proceedings, (iv) the delivery of decisions, (v) the appeal rights of applicants and (vi) the payment of disputed fees, including accumulations of interest. Decisions concerning such disputes are binding on industry members, subject to the rights of any such member to seek redress from the SEC or in any appropriate forum.

Comments on the proposed rule change are due within 21 days of its publication in the Federal Register.