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On March 19, 2020, the Participants of the CAT NMS Plan submitted to the SEC a request for no action relief regarding a temporary delay in near term CAT compliance dates.

The Operating Committee of the CAT NMS Plan has issued a statement on the SEC's No Action Letter related to the Consolidated Audit Trail.

The CAT NMS Plan defines “Small Industry Members” as “an Industry Member that qualifies as a small broker-dealer as defined in SEC Rule 613.” SEC Rule 613, in turn, defines “small broker-dealers” by referring to “those members that qualify as small broker-dealers as defined in §240.0-10(c) of this chapter.” Rule 0-10(c) under the Exchange Act states that the term small business or small organization shall,

[w]hen used with reference to a broker or dealer, mean a broker-dealer that:

No. A firm is a Small Industry Member for purposes of reporting to CAT if its total capital is less than $500,000 on the date on which its audited financial statements were prepared. If the firm’s total capital subsequently exceeds $500,000 prior to the Small Industry Member implementation deadline of December 2021, the firm is not required to begin reporting as a Large Industry Member; rather, the firm must still comply with the Small Industry Member reporting deadline.