SEC Proposes Data Security Amendments To CAT NMS Plan

The SEC proposed amendments to the national market system plan governing the Consolidated Audit Trail (the "CAT NMS Plan") that would (i) increase security requirements for the use of CAT data and (ii) reduce the scope of sensitive information required to be collected.

The proposed amendments to the CAT NMS Plan would, among other things, require the use of "Secure Analytical Workplaces" for the analysis of large CAT data sets and incorporate restrictions for accessing and analyzing customer information, subject to the CAT's "Comprehensive Information Security Program." Additionally, the amendments would modify the Customer-ID creation and reporting processes, specifically removing "sensitive" personally identifiable information (e.g., social security numbers, individual taxpayer identification numbers and account numbers for natural person customers) from CAT reporting requirements. The amendments would require CAT participants to establish, maintain, enforce