SIFMA Urges Reevaluation of Latest CAT Executed Share Funding Model

SIFMA urged the SEC to seek further public input and reevaluate the proposed fee split set out in the CAT Executed Share Funding Model. The proposed revised funding model would allocate a third of the CAT transaction fee to the buyer, a third to the seller and a third to the execution venue of the transactions.

In a comment letter, SIFMA identified several issues with this model, including a lack of sufficient information to determine if the proposed allocation of prospective and past CAT costs to industry members satisfies the Exchange Act's fee standards. Further, SIFMA criticized the lack of consideration of the impact of the proposal on clearing firms, which would be subject to additional fees.