CAT NMS Plan

On December 12, 2024, the SEC approved amendments to the CAT NMS Plan to implement certain cost savings measures, including (A) provisions that would change processing, query, and storage requirements for options market maker quotes in listed options; (B) provisions that would permit the Plan Processor to move raw unprocessed data and interim operational copies of CAT Data older than 15 days to a more cost-effective storage tier; and (C) provisions that would codify and expand exemptive relief recently provided by the Commission related to certain recordkeeping and data retention requirements for industry test data older than three months.

On September 20, 2024, CAT LLC filed with the SEC a letter responding to issues discussed in the SEC’s order instituting proceedings on the Cost Savings Amendment, which was filed with the SEC on March 27, 2024. The proposed changes to the CAT NMS Plan are set forth in Exhibit A of the filing.

On August 2, 2024, CAT LLC filed with the SEC a proposed amendment to the CAT NMS Plan relating to the reporting of certain verbal floor activity and unstructured verbal and electronic upstairs activity.  The proposed changes to the CAT NMS Plan are set forth in Exhibit A of the filing.

On July 31, 2024, the CAT NMS Plan was amended to include MIAX Sapphire, LLC as a Participant.

On June 13, 2024, CAT LLC filed with the SEC a letter responding to public comments regarding the fee filings filed by the Participants for Historical CAT Assessment 1.

On March 27, 2024, CAT LLC filed with the SEC a proposed amendment to the CAT NMS Plan to implement certain cost savings initiatives.  The proposed changes to the CAT NMS Plan are set forth in Exhibit A of the filing.

Effective January 2, 2024, the SEC amended Section 6.4 of the CAT NMS Plan to require the reporting to the CAT of reliance on the bona fide market making exception in Regulation SHO, in connection with the SEC’s issuance of Release No. 34-98738, “Short Position and Short Activity Reporting by Institutional Investment Managers.”  The compliance date for this reporting is July 1, 2025.

On November 9, 2023, CAT LLC withdrew the proposed amendment to the CAT NMS Plan that was filed with the Commission on August 3, 2023, to implement a revised linkage timeline.

This is the version of the CAT NMS Plan effective as of September 6, 2023, as updated to reflect the amendment to the CAT NMS Plan to implement a funding model for the CAT and to establish a fee schedule for Participant CAT fees in accordance with the funding model.

SEC Approved CAT NMS Plan Amendment Related to Funding Proposal

On September 6, 2023, the SEC approved an amendment to the CAT NMS Plan to implement a funding model for the CAT and to establish a fee schedule for Participant CAT fees in accordance with the funding model.

On August 3, 2023, CAT LLC filed with the SEC a proposed amendment to the CAT NMS Plan to implement a revised linkage timeline.  The proposed changes to the CAT NMS Plan are set forth in Exhibit A of the filing.

On July 28, 2023, CAT LLC filed with the SEC a letter responding to public comments regarding the proposed CAT NMS Plan amendment related to the Funding Proposal, which was filed with the SEC on March 13, 2023.

On May 18, 2023, CAT LLC filed with the SEC a letter responding to public comments regarding the proposed CAT NMS Plan amendment related to the Funding Proposal, which was filed with the SEC on March 13, 2023.

On March 13, 2023, CAT LLC filed with the SEC a proposed amendment to the CAT NMS Plan to implement a funding model for the CAT and to establish a fee schedule for Participant CAT fees in accordance with the funding model.  The proposed changes to the CAT NMS Plan are set forth in Exhibit A of the filing.

On March 1, 2023, CAT LLC  submitted a filing to the SEC to withdraw a proposed amendment to the CAT NMS Plan to implement a revised funding model for the CAT and to establish a fee schedule for Participant CAT fees that was originally filed on May 13, 2022 and amended on November 15, 2022 and February 15, 2023. The Participants remain fully committed to establishing appropriate Industry Member and Participant fees.

On February 15, 2023, CAT LLC filed with the SEC a letter responding to public comments regarding Partial Amendment No. 1 to the proposed amendment to the CAT NMS Plan related to the proposed funding model, which was filed with the SEC on May 13, 2022.

On November 15, 2022, CAT LLC filed with the SEC a letter in response to the SEC’s order instituting proceedings to determine whether to approve or disapprove a proposed amendment to the CAT NMS Plan to implement a revised funding model, which was filed with the SEC on May 13, 2022.

On September 8, 2022, the Operating Committee of CAT NMS, LLC filed with the SEC a proposed amendment to the CAT NMS Plan related to the Reporter Agreement and the Reporting Agent Agreement.

On September 6, 2022, the Operating Committee of CAT NMS, LLC filed with the SEC a withdrawal of the proposed amendment to the CAT NMS Plan that was filed with the Securities and Exchange Commission (the “Commission”) on May 20, 2022, and noticed on June 3, 2022 by the Commission. The amendment proposed to revise the Consolidated Audit Trail Reporter Agreement (the “Reporter Agreement”) and the Consolidated Audit Trail Reporting Agent Agreement (the “Reporting Agent Agreement”).

On August 16, 2022, the Operating Committee of the CAT NMS Plan filed with the SEC a letter responding to public comments regarding the proposed amendment to the CAT NMS Plan related to the proposed funding model, which was filed with the SEC on May 13, 2022.

On May 20, 2022, the Operating Committee of CAT NMS, LLC filed with the SEC a proposed amendment to the CAT NMS Plan related to the Reporter Agreement and the Reporting Agent Agreement. 

On May 13, 2022, the Operating Committee of CAT NMS, LLC filed with the SEC a proposed amendment to the CAT NMS Plan to implement a revised funding model (the "Executed Share Model") for the CAT and to establish a fee schedule for Participant CAT fees in accordance with the Executed Share Model. The proposed changes to the CAT NMS Plan, including the fee schedule set forth in proposed Appendix B to the CAT NMS Plan, are set forth in Exhibit A to this letter. 

On December 8, 2021, the Operating Committee of CAT NMS, LLC submitted a filing to the SEC to withdraw a proposed amendment to the CAT NMS Plan to implement a revised funding model for the CAT and to establish a fee schedule for Participant CAT fees. The Participants are fully committed to establishing appropriate Industry Member and Participant fees and determined to withdraw the proposed amendment so that they can continue to assess the funding model.

On July 14, 2021, the Operating Committee of the CAT NMS Plan filed with the SEC a letter responding to public comments regarding the proposed amendment to the CAT NMS Plan related to the proposed funding model, which was filed with the SEC on March 31, 2021. The letter discusses certain comments related to CAT costs, including the level of transparency of such costs, and comments related to the process for developing the proposed funding model.

On July 14, 2021, the Operating Committee of the CAT NMS Plan filed with the SEC a letter responding to public comments regarding the proposed amendment to the CAT NMS Plan related to the proposed funding model, which was filed with the SEC on March 31, 2021. The letter discuses certain comments related to the allocation of CAT costs between Industry Members and Participants, Industry Member CAT fees, Participant CAT fees and the illustrative example of the proposed funding model.

On May 5, 2021, the Operating Committee of the CAT NMS Plan filed with the SEC a comment letter providing additional details on the illustrative example included in the proposed amendment to the CAT NMS Plan related to the revised funding model, which was filed on March 31, 2021. 

On March 31, 2021, the Operating Committee of the CAT NMS Plan filed with the SEC a proposed amendment to the CAT NMS Plan to implement a revised funding model for the CAT and to establish a fee schedule for Participant CAT fees in accordance with the revised funding model.

On December 18, 2020, the Participants in the CAT NMS Plan filed a proposed amendment to the Plan to revise the CAT Reporter Agreement and CAT Reporting Agent Agreement to insert limitation of liability provisions. 

On July 24, 2020, the SEC approved an amendment to the CAT NMS Plan that revises data reporting requirements for the reporting of “Firm Designated ID” to the CAT.  The revisions are reflected in the definition of “Firm Designated ID” in Section 1.1. The SEC’s approval order can be found here: 

https://www.sec.gov/rules/sro/nms/2020/34-89397.pdf

On June 22, 2020, the SEC’s May 15, 2020 amendments to the CAT NMS Plan became effective. The SEC’s amendments add certain new terms to Section 1.1, a new Section 6.6(c) and a new Section 11.6. 

 (6/5/2020)

On June 5, 2020, the CAT NMS Plan was amended to include MEMX LLC as a Participant.

On May 15, 2020, the Securities and Exchange Commission adopted amendments to the CAT NMS Plan. The release adopting the amendments can be found here:

https://www.sec.gov/rules/final/2020/34-88890.pdf

 (4/14/2020)

On April 14, 2020, the Plan Participants submitted to the SEC a proposed amendment to the CAT NMS Plan that would revise data reporting requirements for the reporting of “Firm Designated ID” (“FDID”) to the CAT. The filing amends and replaces prior amendments regarding the reporting of FDID submitted to the SEC on September 26, 2019, November 20, 2019, and February 27, 2020.

 (02/27/2020)

On February 27, 2020, the Plan Participants filed a proposed amendment to the CAT NMS Plan that would revise data reporting requirements for the reporting of “Firm Designated ID” to the CAT.

New Proposed CAT NMS Plan Amendment related to FDID (11/20/2019)

On November 20, 2019, the Participants of the CAT NMS Plan filed a proposal with the SEC to amend the Plan to revise data reporting requirements for the Firm Designated ID (“FDID”). This proposal amends and replaces in its entirety the Participants’ September 26, 2019 filing with the SEC regarding the data reporting requirements for the FDID.

 (10/19/2019)

On October 19, 2019, the CAT NMS Plan was amended to include Long-Term Stock Exchange as a Participant.

Amended CAT NMS Plan for Consolidated Audit Trail, LLC (8/29/2019)

Notice of Filing of Amended CAT NMS Plan for Consolidated Audit Trail, LLC (8/29/2019)

On August 29, 2019, the Operating Committee for CAT NMS, LLC submitted a proposed amendment to the CAT NMS Plan to the SEC. With the proposed amendment, the Limited Liability Company Agreement of a new limited liability company named Consolidated Audit Trail, LLC will serve as the CAT NMS Plan, replacing in its entirety the Limited Liability Company Agreement of CAT NMS, LLC, which previously served as the CAT NMS Plan prior to the filing of the proposed amendment. The content of the CAT NMS Plan will not change except for changes related to the name of the limited liability company, date of the agreement and updates to the list of current Participants

SEC Approved CAT NMS Plan Amended to Include Participant CAT Fees (1/10/2018)

On January 10, 2018, the Operating Committee of CAT NMS, LLC submitted a filing to the SEC to withdraw a proposed amendment to the CAT NMS Plan to add a fee schedule that would set forth the CAT Fees to be paid by the Participants. The Participants are fully committed to establishing equitable Industry Member and Participant fees and determined to withdraw the proposed amendment so that they can continue to assess the proposed funding model

Amendment No. 4 to the SEC Approved CAT NMS Plan to include Participant CAT Fees

New as of 12/11/2017: the SROs filed Amendment No. 4 to the SEC Approved CAT NMS Plan to include Participant CAT Fees

SEC Approved CAT NMS Plan Amended to Include Participant CAT Fees (10/30/2017)

New as of 10/30/17: the SROs filed an amendment for approval to the SEC Approved CAT NMS Plan to include Participant CAT Fees

SEC Approved CAT NMS Plan Amended to Include Participant CAT Fees (7/21/2017)

On July 21, 2017, the SEC issued an order summarily abrogating the SROs’ amendment to the CAT NMS Plan regarding proposed Participant CAT Fees. This version of the CAT NMS Plan removes the exhibit discussing the proposed Participant CAT Fees.

SEC Approved CAT NMS Plan Amended to Include Participant CAT Fees (5/22/2017)

On May 22, 2017, the SROs filed an Amendment to the SEC Approved CAT NMS Plan to include Participant CAT Fees.

SEC Approved CAT NMS Plan Amended to Include MIAX Pearl (1/11/2017)

On January 11, 2017, the SROs filed an Amendment to the SEC Approved CAT NMS Plan to include MIAX Pearl.

SEC Approved CAT NMS Plan (11/15/2016)

On November 15, 2016, the Commission unanimously approved the CAT NMS Plan.

SEC Notice of Filing of the Consolidated Audit Trail National Market System Plan and Request for Comment (5/17/2016)

On May 17, 2016, the Commission published the Amended and Restated CAT NMS Plan and requested public comments.

Clean Version of the 12/23/15 Amended and Restated Consolidated Audit Trail National Market System Plan (CAT NMS Plan) Submission (2/9/2016)

On February 9, 2016, the SROs filed an identical, but unmarked version of the 12/23/15 Amended and Restated CAT NMS Plan.

12/23/15 Amended and Restated CAT NMS Plan Submission (12/23/2015)

On December 23, 2015, the SROs filed an Amendment to the Amended and Restated CAT NMS Plan (12/23/15 Amended and Restated CAT NMS Plan).

Amended and Restated CAT NMS Plan Submission (2/27/2015)

On February 27, 2015, the SROs filed an Amended and Restated Consolidated Audit Trail National Market System Plan to replace the Initial CAT NMS Plan (“Amended and Restated CAT NMS Plan").

Initial CATNMS Plan Submission (9/30/2014)

On September 30, 2014, the SROs filed the Consolidated Audit Trail National Market System Plan (“Initial CAT NMS Plan”).