Key takeaways

• After four years of collaboration amongst the self-regulatory organizations ("SROs"), the SEC has released for comment the SROs joint rule proposal of the consolidated audit trail plan (the “CAT Plan”) to create the most robust and complicated financial database in the world relating to equity and options market activity.
• The CAT Plan represents the SEC’s recognition of the importance of technology in financial markets and the SROs need develop tools to regulate the marketplace through technology.
• The Industry has raised concerns with the CAT Plan related to governance, data security and privacy, and overall cost to the industry, amongst others.