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November 9, 2023


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.

September 6, 2023


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.

September 6, 2023

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.

August 3, 2023

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.

July 28, 2023

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.

May 18, 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.

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.

March 1, 2023

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.

February 15, 2023

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.

November 15, 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.

September 8, 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.

September 6, 2022

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”).

August 16, 2022

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.

May 20, 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. 

May 13, 2022

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. 

December 8, 2021

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.

July 14, 2021

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.

July 14, 2021

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.

May 5, 2021

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. 

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.

December 18, 2020

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. 

July 24, 2020

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

June 22, 2020

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. 

June 5, 2020

 (6/5/2020)

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

May 15, 2020

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

April 14, 2020

 (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.

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.

November 20, 2019

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.

October 19, 2019

 (10/19/2019)

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

September 26,2019Proposed FDID Amendment (9/26/2019)
August 29, 2019

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

January 10, 2018

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

December 11, 2017

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

October 30, 2017

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

July 21, 2017

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.

May 22, 2017

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.

January 11, 2017

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.

November 15, 2016

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

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

May 17, 2016

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.

February 9, 2016

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.

March 24, 2016CAT NMS Plan Security Requirements – Architecture, Program and Data Usage Controls
December 23, 2015

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).

February 27, 2015

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").

September 30, 2014

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”).