The CAT NMS Plan requires the Participants to submit rule filings to eliminate or modify any rules or systems that would be redundant of the CAT. In May 2017, certain Participants filed with the SEC rule filings to eliminate or modify certain redundant rules and systems, including rule filings related to FINRA’s Order Audit Trail System (“OATS”) and the Electronic Blue Sheets (“EBS”). In light of the delay in the commencement of CAT reporting, these rule filings were withdrawn. In August 2020, FINRA filed with the SEC a proposed rule change to eliminate the OATS Rules once members were effectively reporting to the CAT. The filing states that the proposed rule change only addresses the elimination of the OATS Rules and that amendments to the EBS Rules would be subject to a separate FINRA rule filing made in conjunction with SEC rulemaking to amend Rule 17a-25 under the Exchange Act. FINRA removed the OATS Rules on September 1, 2021 and retired the system on September 16, 2021 (See Regulatory Notice 21-21).