Key takeaways

• On November 15, 2016, the Securities and Exchange Commission ("SEC") approved a plan to create a comprehensive trade reporting system that will allow regulators to access all trade activity in U.S. equity and options markets (the "CAT Plan").
• The final approved CAT Plan contains a few significant amendments in response to industry feedback, including stronger data security requirements, tightening clock synchronization standards, enhancing governance, and accelerating the deadline for proposals to retire obsolete data reporting systems.
• Data security should continue to be a focus as the CAT Plan is implemented by the plan processor, expected to be selected in the next two months.