SEC Request For Comment On Proposed CAT Plan Published (Fed. Reg.)

The SEC solicited comment 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 request for comment was published in the Federal Register.

The proposed CAT plan was submitted jointly to the SEC by FINRA and the national securities exchanges (the "SROs"). The plan 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, among other things, be responsible for (i) operating, maintaining, and upgrading the central repository, (ii) ensuring the