Proposed Amendment to the CAT NMS Plan Would Save Operating Costs

Consolidated Audit Trail, LLC ("CAT LLC"), on behalf of numerous exchanges, proposed a "2025 Cost Savings Amendment" to the National Market System Plan Governing the Consolidated Audit Trail (the "CAT NMS Plan") to reduce operating costs by approximately $55 million to $73 million annually through various technical and operational restructurings.

Under the joint industry plan, the amendment would codify and expand upon relief granted in a "2025 Cost Savings Exemptive Order" without compromising the system's core regulatory functionality. The proposal would introduce a new "Reference Data Approach" to replace the current Customer & Account Information System ("CAIS"). Under this model, Industry Members would report a subset of data using hashed identifiers to a Reference Database, thereby eliminating the CAIS system while preserving the ability to generate a CAT-Customer-ID ("CCID").

In addition to the Reference Data Approach, the exchanges proposed several other cost-saving measures, including:

• Data Storage: Reducing retention periods for general CAT data from six years to three years, and reducing retention for OMM quotes and Options SIP data to six months;
• Late Data Processing: Eliminating the "Full Replay" re-processing requirement for late or corrected data received after T+4;
• Data Availability: Adjusting timelines for regulator access, making raw data available by T+2 and final corrected data by T+6; and
• Tool Rationalization: Eliminating the requirement to provide the Online Targeted Query Tool and the daily assignment of interim CAT-Order-IDs.

The amendment also includes a governance provision regarding spending caps. The new rule would require that any modification to CAT functionality that materially increases operating expenses be approved via a formal CAT NMS Plan amendment or Commission order, unless the change is strictly necessary for security or maintaining existing functionality.

CAT LLC noted that it rejected alternatives such as the full elimination of the CCID based on industry feedback, as retaining the identifier helps avoid increased Electronic Blue Sheet requests.