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The SEC disapproved proposed amendments to the National Market System Plan Governing the Consolidated Audit Trail ("CAT"). The amendments would have provided for limited liability to industry members reporting to the CAT, and limited the liability of the Operating Committee and its participants in the case of a systems breach or misuse.

Commentary by Steven Lofchie

The SEC proposed amendments to the national market system plan governing the Consolidated Audit Trail that would (i) increase security requirements for the use of collected data and (ii) reduce the scope of sensitive information required to be collected.