SEC Approves Request For Comments On Proposed CAT Plan (With Delta Strategy Group Summary)

SEC Commissioners voted unanimously to publish and request comments on a proposed national market system plan that would create a single, comprehensive database of all trading activity in the U.S. equity and options markets (the "consolidated audit trail" or "CAT" plan). The proposed CAT plan was submitted to the SEC by FINRA and the national securities exchanges (the "SROs") jointly. It is intended to improve regulators' ability to perform market research and monitoring, effect event reconstruction, and identify and investigate market misconduct.

Highlights from the proposed CAT plan include the following:

Plan Processor and Central Repository. Under the CAT plan, a plan processor would build a central repository for receiving, consolidating, and retaining reported trade and order data. The plan processor would be responsible for, among other things, (i) operating, maintaining, and upgrading the central repository, (ii) ensuring the security and confidentiality