An SEC proposal to facilitate the implementation of the Consolidated Audit Trail ("CAT") was published in the Federal Register. Comments on the proposal must be submitted by October 28, 2019.

As previously covered, the proposal would require FINRA and the securities exchanges to publish a comprehensive CAT implementation plan and present quarterly progress reports that must be approved by a supermajority vote of the Operating Committee of CAT NMS, LLC. In addition, the SEC proposed target deadlines for four CAT implementation milestones and a reduction in the fees that self-regulatory organizations and securities exchanges may recover from broker-dealers if the target deadlines are missed.

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