SEC Extends Exemptive Relief on Reporting CAT Order Linkages

The SEC extended exemptive relief on certain CAT NMS Plan requirements that mandate reporting linkages between customer orders and representative orders. The new Order extends the relief until January 31, 2026.

The exemptive relief, originally granted in 2020, concerns Appendix D, Section 3 of the CAT NMS Plan, which requires Industry Members to report linkages between customer orders and representative orders—such as those handled on a riskless principal basis. The requirement applies to scenarios where a firm routes a proprietary order to the market to fulfill a customer order. The SEC issued a series of exemptive orders over the last several years delaying enforcement of this provision, most recently in January 2025.

In its request for continued relief, the Financial Information Forum ("FIF") cited persistent operational challenges faced by Industry Members. FIF explained that in certain scenarios, representative orders do not exist or are not linked systematically between order management and execution management systems. FIF also highlighted that the CAT system currently lacks a mechanism to accommodate these gaps, and that enforcing the linkage requirement would force firms to submit large volumes of rejected Order Fulfillment events, abandon common trading workflows, or refrain from reporting altogether.