Notice2023-19525

Joint Industry Plan; Order Approving an Amendment to the National Market System Plan Governing the Consolidated Audit Trail; Notice

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Published
September 12, 2023

Issuing agencies

Securities and Exchange Commission

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[Federal Register Volume 88, Number 175 (Tuesday, September 12, 2023)]
[Notices]
[Pages 62628-62686]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2023-19525]



[[Page 62627]]

Vol. 88

Tuesday,

No. 175

September 12, 2023

Part II





Securities and Exchange Commission





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Joint Industry Plan; Order Approving an Amendment to the National 
Market System Plan Governing the Consolidated Audit Trail; Notice

Federal Register / Vol. 88, No. 175 / Tuesday, September 12, 2023 / 
Notices

[[Page 62628]]


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SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-98290; File No. 4-698]


Joint Industry Plan; Order Approving an Amendment to the National 
Market System Plan Governing the Consolidated Audit Trail; Notice

September 6, 2023.

I. Introduction

    On March 13, 2023, the Consolidated Audit Trail, LLC (``CAT LLC''), 
on behalf of the Participants \1\ to the National Market System Plan 
Governing the Consolidated Audit Trail (``CAT NMS Plan'' or 
``Plan''),\2\ filed with the Securities and Exchange Commission 
(``Commission''), pursuant to Section 11A of the Exchange Act \3\ and 
Rule 608 of Regulation National Market System (``Regulation NMS'') 
thereunder,\4\ a proposed amendment to the CAT NMS Plan (``Proposed 
Amendment'') to implement a revised funding model (``Executed Share 
Model'') for the consolidated audit trail (``CAT'') \5\ and to 
establish a fee schedule for Participant CAT fees in accordance with 
the Executed Share Model (``Proposed Participant Fee Schedule'').\6\ 
The Proposed Amendment was published for comment in the Federal 
Register on March 21, 2023.\7\
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    \1\ The Participants are: BOX Exchange LLC, Cboe BYX Exchange, 
Inc., Cboe BZX Exchange, Inc., Cboe C2 Exchange, Inc., Cboe EDGA 
Exchange, Inc., Cboe EDGX Exchange, Inc., Cboe Exchange, Inc., The 
Financial Industry Regulatory Authority, Inc. (``FINRA''), Investors 
Exchange LLC, Long-Term Stock Exchange, Inc., MEMX LLC, Miami 
International Securities Exchange, LLC, MIAX Emerald, LLC, MIAX 
PEARL, LLC, Nasdaq BX, Inc., Nasdaq GEMX, LLC, Nasdaq ISE, LLC, 
Nasdaq MRX, LLC, Nasdaq PHLX LLC, The Nasdaq Stock Market LLC, New 
York Stock Exchange LLC, NYSE American LLC, NYSE Arca, Inc., NYSE 
Chicago, Inc., and NYSE National, Inc. (collectively, the 
``Participants,'' ``self-regulatory organizations,'' or ``SROs'').
    \2\ The CAT NMS Plan is a national market system plan approved 
by the Commission pursuant to Section 11A of the Securities Exchange 
Act of 1934 (``Exchange Act'') and the rules and regulations 
thereunder. See Securities Exchange Act Release No. 78318 (Nov. 15, 
2016), 81 FR 84696 (Nov. 23, 2016) (``CAT NMS Plan Approval 
Order''). The CAT NMS Plan is Exhibit A to the CAT NMS Plan Approval 
Order. See CAT NMS Plan Approval Order, 81 FR at 84943-85034. The 
CAT NMS Plan functions as the limited liability company agreement of 
the jointly owned limited liability company formed under Delaware 
state law through which the Participants conduct the activities of 
the CAT (``Company''). Each Participant is a member of the Company 
and jointly owns the Company on an equal basis. The Participants 
submitted to the Commission a proposed amendment to the CAT NMS Plan 
on August 29, 2019, which they designated as effective on filing. On 
August 29, 2019, the Participants replaced the CAT NMS Plan in its 
entirety with the limited liability company agreement of a new 
limited liability company, CAT LLC, which became the Company. See 
Securities Exchange Act Release No. 87149 (Sept. 27, 2019), 84 FR 
52905 (Oct. 3, 2019). The latest version of the CAT NMS Plan is 
available at <a href="https://catnmsplan.com/about-cat/cat-nms-plan">https://catnmsplan.com/about-cat/cat-nms-plan</a>.
    \3\ 15 U.S.C. 78k-1.
    \4\ 17 CFR 242.608.
    \5\ The Proposed Amendment modifies the existing funding model 
in Article XI. of the CAT NMS Plan.
    \6\ See Letter from Brandon Becker, Chair, CAT NMS Plan 
Operating Committee, to Vanessa Countryman, Secretary, Commission 
(Mar. 13, 2023) (``Transmittal Letter'').
    \7\ See Securities Exchange Act Release No. 97151 (Mar. 15, 
2023), 88 FR 17086 (Mar. 21, 2023) (``Notice''). Comments received 
in response to the Notice can be found on the Commission's website 
at <a href="https://www.sec.gov/comments/4-698/4-698-a.htm">https://www.sec.gov/comments/4-698/4-698-a.htm</a>.
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    On June 16, 2023, the Commission instituted proceedings pursuant to 
Rule 608(b)(2)(i) of Regulation NMS \8\ to determine whether to 
disapprove the Proposed Amendment or to approve the Proposed Amendment 
with any changes or subject to any conditions the Commission deems 
necessary or appropriate after considering public comment (``OIP'').\9\
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    \8\ 17 CFR 242.608(b)(2)(i).
    \9\ See Securities Exchange Act Release No. 97750 (June 16, 
2023), 88 FR 41142 (June 23, 2023). Comments received in response to 
the OIP can be found on the Commission's website at <a href="https://www.sec.gov/comments/4-698/4-698-a.htm">https://www.sec.gov/comments/4-698/4-698-a.htm</a>.
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    This order approves the Proposed Amendment.

II. Background

    On July 11, 2012, the Commission adopted Rule 613 of Regulation 
NMS, which required the SROs to submit a national market system 
(``NMS'') plan to create, implement and maintain a consolidated audit 
trail that would capture customer and order event information for 
orders in NMS securities.\10\ On November 15, 2016, the Commission 
approved the CAT NMS Plan.\11\ Under the CAT NMS Plan, the Operating 
Committee of the Company, of which each Participant is a member, has 
the discretion (subject to the funding principles set forth in the 
Plan) to establish funding for the Company to operate the CAT, 
including establishing fees to be paid by the Participants and Industry 
Members.\12\
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    \10\ 17 CFR 242.613.
    \11\ See CAT NMS Plan, supra note 2.
    \12\ The CAT NMS Plan defines ``Industry Member'' as ``a member 
of a national securities exchange or a member of a national 
securities association.'' See CAT NMS Plan, supra note 2, at Section 
1.1. See also id. at Section 11.1(b).
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    Under the CAT NMS Plan, CAT fees are to be implemented in 
accordance with various funding principles, including an ``allocation 
of the Company's related costs among Participants and Industry Members 
that is consistent with the Exchange Act taking into account . . . 
distinctions in the securities trading operations of Participants and 
Industry Members and their relative impact upon the Company resources 
and operations'' and the ``avoid[ance of] any disincentives such as 
placing an inappropriate burden on competition and reduction in market 
quality.'' \13\ The Plan specifies that, in establishing the funding of 
the Company, the Operating Committee shall establish ``a tiered fee 
structure in which the fees charged to: (1) CAT Reporters \14\ that are 
Execution Venues,\15\ including ATSs,\16\ are based upon the level of 
market share; (2) Industry Members' non-ATS activities are based upon 
message traffic; and (3) the CAT Reporters with the most CAT-related 
activity (measured by market share and/or message traffic, as 
applicable) are generally comparable (where, for these comparability 
purposes, the tiered fee structure takes into consideration 
affiliations between or among CAT Reporters, whether Execution Venues 
and/or Industry Members).'' \17\
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    \13\ Id. at Section 11.2(b) and (e).
    \14\ The CAT NMS Plan defines ``CAT Reporter'' as ``each 
national securities exchange, national securities association and 
Industry Member that is required to record and report information to 
the Central Repository pursuant to SEC Rule 613(c).'' Id. at Section 
1.1.
    \15\ The CAT NMS Plan defines ``Execution Venue'' as ``a 
Participant or an alternative trading system (`ATS') (as defined in 
Rule 300 of Regulation ATS) that operates pursuant to Rule 301 of 
Regulation ATS (excluding any such ATS that does not execute 
orders).'' Id.
    \16\ Id.
    \17\ CAT NMS Plan, supra note 2, at Section 11.2(c). See id. at 
Article XI for additional detail.
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    On May 15, 2020, the Commission adopted amendments to the CAT NMS 
Plan designed to increase the Participants' financial accountability 
for the timely completion of the CAT (``Financial Accountability 
Amendments'').\18\ The Financial Accountability Amendments added 
Section 11.6 to the CAT NMS Plan to govern the recovery from Industry 
Members of any fees, costs, and expenses (including legal and 
consulting fees, costs and expenses) incurred by or for the Company in 
connection with the development, implementation and operation of the 
CAT from June 22, 2020 until such time that the Participants have 
completed Full Implementation of CAT NMS Plan Requirements \19\ 
(``Post-Amendment

[[Page 62629]]

Expenses''). Section 11.6 establishes target deadlines for four 
Financial Accountability Milestones (Periods 1, 2, 3 and 4) \20\ and 
reduces the amount of fee recovery available to the Participants if 
these deadlines are missed.\21\
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    \18\ See Securities Exchange Act Release No. 88890, 85 FR 31322 
(May 22, 2020).
    \19\ ``Full Implementation of CAT NMS Plan Requirements'' means 
``the point at which the Participants have satisfied all of their 
obligations to build and implement the CAT, such that all CAT system 
functionality required by Rule 613 and the CAT NMS Plan has been 
developed, successfully tested, and fully implemented at the initial 
Error Rates specified by Section 6.5(d)(i) or less, including 
functionality that efficiently permits the Participants and the 
Commission to access all CAT Data required to be stored in the 
Central Repository pursuant to Section 6.5(a), including Customer 
Account Information, Customer-ID, Customer Identifying Information, 
and Allocation Reports, and to analyze the full lifecycle of an 
order across the national market system, from order origination 
through order execution or order cancellation, including any related 
allocation information provided in an Allocation Report. This 
Financial Accountability Milestone shall be considered complete as 
of the date identified in a Quarterly Progress Report meeting the 
requirements of Section 6.6(c).'' CAT NMS Plan, supra note 2, at 
Section 1.1.
    \20\ See CAT NMS Plan, supra note 2, at Section 11.6(a)(i).
    \21\ Id. at Section 11.6(a)(ii) and (iii).
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III. Discussion and Commission Findings

    After careful review, the Commission, pursuant to Section 11A of 
the Exchange Act,\22\ and Rule 608(b)(2) \23\ thereunder, is approving 
the Proposed Amendment. Section 11A of the Exchange Act authorizes the 
Commission, by rule or order, to authorize or require the self-
regulatory organizations to act jointly with respect to matters as to 
which they share authority under the Exchange Act in planning, 
developing, operating, or regulating a facility of the national market 
system.\24\ Rule 608 of Regulation NMS authorizes two or more SROs, 
acting jointly, to file with the Commission proposed amendments to an 
effective NMS plan,\25\ and further provides that the Commission shall 
approve an amendment to an effective NMS plan if it finds that the 
amendment is necessary or appropriate in the public interest, for the 
protection of investors and the maintenance of fair and orderly 
markets, to remove impediments to, and perfect the mechanisms of, a 
national market system, or otherwise in furtherance of the purposes of 
the Exchange Act.\26\
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    \22\ 15 U.S.C. 78k-1.
    \23\ 17 CFR 242.608(b)(2).
    \24\ See 15 U.S.C. 78k-1(a)(3)(B).
    \25\ See 17 CFR 242.608.
    \26\ See 17 CFR 242.608(b)(2).
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    The Participants have sufficiently demonstrated that the proposed 
allocation of fees is reasonable. There are a number of potential 
approaches to allocating the costs of operating the CAT, all of which 
have relative strengths and weaknesses. In adopting Rule 613 and 
approving the CAT NMS Plan, the Commission determined that the CAT was 
appropriate in order to enable the SROs and the Commission to fulfill 
their responsibilities to oversee the equities and options markets. The 
CAT NMS Plan requires both Execution Venues (which include the 
Participants) and Industry Members (which include CAT Executing 
Brokers) to fund the CAT. The proposed one-third allocation of CAT fees 
to the applicable Participant in a transaction, the CAT Executing 
Broker for the buyer in a transaction and the CAT Executing Broker for 
the seller in a transaction, assesses an equal fee to the three primary 
roles in a transaction: the buyer, seller and market regulator. In our 
view, allocating the costs for the CAT among the three parties who play 
significant roles in transactions reportable to the CAT in this manner 
represents a reasonable method of allocating costs among the parties 
who participate in and benefit from those markets.
    Commenters expressed concern that the Participant exchanges and 
FINRA would pass their share of costs on to Industry Members. But the 
Exchange Act expressly contemplates the ability of the Participants to 
recoup the costs of fulfilling their statutory obligations under the 
Exchange Act. And, as we explained in adopting Rule 613 and approving 
the CAT NMS Plan, the CAT is important to the performance of these 
regulatory activities in modern, interconnected markets, to the 
ultimate benefit of investors and market participants. Moreover, these 
costs will not be unchecked. The Participants must file their proposed 
rule changes relating to fees with the Commission. Those proposed rule 
changes are published by the Commission and there is an opportunity for 
public comment. CAT fees, like any fees the Participants collect from 
their members to fund their SRO responsibilities in market and member 
regulation, must be consistent with applicable statutory standards 
under the Exchange Act, including being reasonable, equitable and not 
unfairly discriminatory.
    We also conclude that the use of executed equivalent share volume 
provides a reasonable basis for the calculation of these fees. Executed 
equivalent share volume is readily determinable and--because it is 
based on trading activity, which impacts CAT costs--provides a 
reasonable proxy for the costs to CAT, allowing CAT Reporters to be 
assessed fees corresponding to the cost burden they impose on the CAT. 
The use of CAT Executing Brokers is also appropriate because the 
proposed Executed Share Model is based on executed equivalent shares 
(emphasis added). Therefore, charging the CAT Executing Brokers would 
reflect their executing role in each transaction, which is already 
recorded in transaction reports from the exchanges and FINRA's equity 
trade reporting facilities for calculating the CAT fees. Because such 
entities are already identified and their CAT fees are known, this 
method could streamline the billing process and allow such entities to 
calculate their own fees. We also conclude that the division of fees 
into Prospective CAT Fees and the Historical CAT Assessment provides a 
reasonable method of allowing Participants to recoup their significant 
expenditures on the development of CAT to date while ensuring funding 
for future operations of the system. And the provision of fee 
calculation information, approach to billing and collection of fees, 
conforming changes and the Proposed Participant Fee Schedule are all 
reasonable. The Commission is therefore approving the Proposed 
Amendment.\27\
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    \27\ Id.
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A. Funding Model

1. Overview
    CAT LLC proposes to replace the funding model set forth in Article 
XI of the CAT NMS Plan (``Original Funding Model'') with the Executed 
Share Model. The Original Funding Model involved a bifurcated approach, 
where costs associated with building and operating the CAT would be 
borne by (1) Industry Members (other than alternative trading systems 
(``ATSs'') that execute transactions in Eligible Securities 
(``Execution Venue ATSs'')) through fixed tiered fees based on message 
traffic for Eligible Securities, and (2) Participants and Industry 
Members that are Execution Venue ATSs for Eligible Securities through 
fixed tiered fees based on market share.\28\ In contrast, the Executed 
Share Model would charge fees based on the executed equivalent share 
volume of transactions in Eligible Securities.\29\ In addition, instead 
of charging fees to Industry Members, under the Executed Share Model, 
fees would be charged to each Industry Member that is a CAT Executing 
Broker \30\ for the buyer in a transaction in Eligible Securities 
(``CAT Executing Broker for the Buyer'' or ``CEBB'') and each Industry 
Member that is the CAT Executing Broker for the seller in a transaction 
in Eligible

[[Page 62630]]

Securities (``CAT Executing Broker for the Seller'' or ``CEBS'').\31\
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    \28\ See CAT NMS Plan, supra note 2, at Section 11.3(a) and (b).
    \29\ See Notice, supra note 7, 88 FR at 17086.
    \30\ See infra Section III.A.4. for the definition of CAT 
Executing Broker.
    \31\ See Notice, supra note 7, 88 FR at 17087.
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    Under the Executed Share Model, CAT LLC proposes to establish two 
categories of CAT fees. The first category of CAT fees would be fees 
(``CAT Fees'') payable by Participants and Industry Members that are 
CAT Executing Brokers for the Buyer and for the Seller with regard to 
CAT costs not previously paid by the Participants (``Prospective CAT 
Costs'').\32\ The second category of CAT fees would be fees 
(``Historical CAT Assessments'') to be payable by Industry Members that 
are CAT Executing Brokers for the Buyer and for the Seller with regard 
to CAT costs previously paid by the Participants (``Past CAT 
Costs'').\33\
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    \32\ Id. at 17086; see also proposed Section 11.3(a). The 
defined term ``CAT Fees'' applies specifically to CAT fees related 
to Prospective CAT Costs. Id.
    \33\ See Notice, supra note 7, 88 FR at 17086; see also proposed 
Section 11.3(b).
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    For each category of fees, each CEBB and each CEBS will be required 
to pay a CAT fee for each such transaction in Eligible Securities in 
the prior month based on CAT Data.\34\ The CEBB's CAT fee or CEBS's CAT 
fee (as applicable) for each transaction in Eligible Securities will be 
calculated by multiplying the number of executed equivalent shares in 
the transaction by one-third and by the reasonably determined Fee 
Rate,\35\ as described below.\36\ Participants would incur CAT Fees 
only for Prospective CAT Costs and the Participant CAT Fee will be 
calculated by multiplying the number of executed equivalent shares in 
the transaction by one-third and by the reasonably determined Fee 
Rate.\37\ The Participants' one-third share of Historical CAT Costs 
\38\ and such other additional Past CAT Costs as reasonably determined 
by the Operating Committee will be paid by the cancellation of loans 
made to the Company on a pro rata basis based on the outstanding loan 
amounts due under the loans.\39\
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    \34\ See Notice, supra note 7, 88 FR at 17093; see also proposed 
Section 11.3(a)(iii), proposed Section 11.3(b)(iii).
    \35\ See infra Section III.A.5.a. (Prospective CAT Fees--Fee 
Rate Formula) for the definition and description of the calculation 
of the Fee Rate. See also infra notes 1100-1102 and accompanying 
text (stating that the anticipated CAT Fee Rate and the fee rate for 
Historical CAT Assessments are expected to be relatively small).
    \36\ See Notice, supra note 7, 88 FR at 17095; see also proposed 
Section 11.3(a)(iii), proposed Section 11.3(b)(iii).
    \37\ See Notice, supra note 7, 88 FR at 17094; see also proposed 
Section 11.3(a)(ii).
    \38\ The actual amount of Past CAT Costs to be recovered through 
the Historical CAT Assessments would be reduced by an amount of 
``Excluded Costs.'' The resulting amount would be defined as 
``Historical CAT Costs'' in proposed Section 11.3(b)(i)(C) of the 
CAT NMS Plan. See infra Section III.A.6.a. for a discussion of 
Historical CAT Costs.
    \39\ See proposed Section 11.3(b)(ii).
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    FINRA CAT would be responsible for calculating the CAT fees and 
submitting invoices to the CAT Executing Brokers based on this CAT 
Data.\40\ All data used to calculate the fees under the Executed Share 
Model would be CAT Data, and, therefore, it would be directly available 
through the CAT to FINRA CAT for calculating CAT fees.\41\
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    \40\ See Notice, supra note 7, 88 FR at 17088.
    \41\ Id.
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    Once the Proposed Amendment has been approved by the Commission, 
the Participants would separately file proposed rule filings pursuant 
to Section 19(b) of the Exchange Act \42\ to establish the amounts of 
the proposed CAT Fees and Historical CAT Assessments to be charged to 
Industry Members, subject to the satisfaction of applicable Financial 
Accountability Milestones as set forth in Section 11.6 of the CAT NMS 
Plan and the implementation of the billing and collection system for 
the CAT fees.\43\ In each proposed rule filing, if the Participants 
seek to recover amounts under the Financial Accountability Milestones, 
they would need to discuss their completion of the applicable 
milestone.\44\
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    \42\ 15 U.S.C. 78s(b).
    \43\ See Notice, supra note 7, 88 FR at 17086, 17122.
    \44\ Proposed Section 11.3(b)(iii)(B)(III) would prohibit any 
Participant from filing proposed rule filings pursuant to Section 
19(b) of the Exchange Act regarding any Historical CAT Assessment 
until any applicable Financial Accountability Milestone in Section 
11.6 of the CAT NMS Plan has been satisfied.
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2. Allocation of Fee Among Participants and Industry Members
    Under the Executed Share Model, CAT fees would be allocated one-
third to the applicable Participant, one-third to the CEBS and one-
third to the CEBB of a transaction. Certain commenters opposed the 
proposed allocation.\45\
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    \45\ See Letters to Vanessa Countryman, Secretary, Commission, 
from Stephen John Berger, Managing Director, Global Head of 
Government and Regulatory Policy, Citadel Securities, dated July 14, 
2023 (``Citadel July Letter''); August 22, 2023 (``Citadel August 
Letter''); Marcia E. Asquith, Corporate Secretary, EVP, Board and 
External Relations, FINRA, dated May 25, 2023 (``FINRA May 2023 
Letter''); April 11, 2023 (``FINRA April 2023 Letter''); and June 
22, 2022 (``FINRA June 2022 Letter'') (the FINRA June 2022 Letter 
was submitted in response to the prior funding proposal and was 
attached and incorporated by reference in the FINRA April 2023 
Letter); Ellen Greene, Managing Director, Equities & Options Market 
Structure, and Joseph Corcoran, Managing Director, Associate General 
Counsel, SIFMA, dated July 13, 2023 (``SIFMA July 2023 Letter''); 
June 5, 2023 (``SIFMA June 2023 Letter''); May 2, 2023 (``SIFMA May 
2023 Letter''); January 12, 2023 (``SIFMA January 2023 Letter''); 
December 14, 2022 (``SIFMA December 2022 Letter''); October 7, 2022 
(``SIFMA October 2022 Letter''); and June 22, 2022 (``SIFMA June 
2022 Letter'') (the SIFMA June 2022 Letter, SIFMA October 2022 
Letter, SIFMA December 2022 Letter and SIFMA January 2023 Letter 
were submitted in response to the prior funding proposal and 
incorporated by reference in the SIFMA May 2023 Letter); Joanna 
Mallers, Secretary, FIA Principal Traders Group, dated July 14, 2023 
(``FIA Letter''); Douglas A. Cifu, Chief Executive Officer, Virtu 
Financial, dated July 13, 2023 (``Virtu Letter''). See infra note 
58.
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    FINRA stated that, while the Proposed Amendment justified the 
fairness of the Executed Share Model because it would operate like 
other fees, like FINRA's Trading Activity Fee (``TAF''), Section 31 
fees, and the options regulatory fee,\46\ the Proposed Amendment did 
not support why those fee frameworks should be used as a model in this 
context.\47\ For example, FINRA stated that the TAF is designed to 
recover the costs of FINRA's regulatory activities, while the CAT fees 
are intended to align with the costs to build, operate and administer 
the CAT.\48\ Further, FINRA stated that the Proposed Amendment has 
insufficiently explained the connection between the TAF and CAT fees, 
merely stating that they are similar fees because they are transaction-
based fees used to provide funding for regulatory costs.\49\ FINRA 
stated that ``CAT LLC's observations superficially focus on the fact 
that these fees also use transaction-based metrics (and may be assessed 
on members) and neglects other factors relevant to the analysis 
including, for example, that these fees are used in combination with 
other funding mechanisms and metrics to support an overall funding 
framework.'' \50\
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    \46\ See Notice, supra note 7, 88 FR at 17122.
    \47\ See FINRA June 2022 Letter at 4.
    \48\ See FINRA April 2023 Letter at 8.
    \49\ Id. The commenter also stated that ``it is unclear how 
assessing on FINRA the largest allocation of the SRO portion of CAT 
expenses `provides funding for regulatory costs' in any reasonable 
and equitable sense comparable to the TAF . . .'' Id.
    \50\ FINRA May 2023 Letter at 3.
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    Another commenter stated that the proposed CAT funding model cannot 
be compared to Section 31 fees, the TAF, or the options regulatory fee 
because the commenter believes that CAT fees appear to be unconstrained 
and out of the industry's control.\51\ The commenter explained that, 
unlike the proposed CAT fees, Section 31 fees are based on an annual 
budget set by Congress and the options regulatory fee is only applied 
to customer transactions and thus can be easily passed-on to other 
market participants (unlike CAT fees for market making activity).\52\ 
Additionally,

[[Page 62631]]

the commenter stated that there is no precedent for fees to be 
allocated to Industry Members in perpetuity, stating that this would 
contravene the Exchange Act.\53\
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    \51\ Citadel July Letter at 27.
    \52\ Id. The commenter also stated that FINRA has sought to 
avoid increases in the TAF. Id.
    \53\ Id. This commenter stated that it is inequitable to require 
Industry Members to fund CAT costs in perpetuity when they lack 
representation on the Operating Committee and therefore have little 
transparency into the drivers of the costs, and there is no plan to 
contain the costs. See id. at 2.
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    One commenter disagreed with the Participants' statement that the 
Executed Share Model's similarity to other transaction-based fees 
approved by the Commission is adequate justification for consistency 
with the Exchange Act.\54\ The commenter stated that similarity to 
other transaction-based fees is not an adequate basis to show that the 
Executed Share Model is consistent with relevant standards; each 
proposed fee must be individually supported.\55\ For example, the 
commenter stated that the Participants compared the Executed Share 
Model to Section 31 fees as justification for the Executed Share Model, 
but failed to address the differences between the Executed Share Model 
and Section 31 fees, such as the Executed Share Model's treatment of 
high-volume trades in low-priced stocks while Section 31 fees are based 
on the notional value of a trade.\56\
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    \54\ See SIFMA June 2022 Letter at 4.
    \55\ Id.
    \56\ See SIFMA October 2022 Letter at 7. See also Citadel August 
Letter at 5.
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    Commenters also questioned the Participants' justifications for the 
one-third allocation methodology. FINRA stated that the Proposed 
Amendment did not justify why the proposed allocation by thirds to the 
Participant, buy-side and sell-side is equitable in the context of the 
CAT NMS Plan.\57\ FINRA also stated that the Proposed Amendment did not 
consider alternatives suggested by commenters on a prior proposed 
funding model,\58\ such as a model similar to Section 31 fees and a CAT 
funding model based on the ``Cost Recovery Principle'' and the 
``Benefits Received Principle.'' \59\ FINRA urged the Commission to 
require those alternatives to be analyzed.\60\
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    \57\ See FINRA June 2022 Letter at 3.
    \58\ See Securities Exchange Act Release Nos. 94984 (May 25, 
2022), 87 FR 33226 (June 1, 2022); 96394 (Nov. 28, 2022), 87 FR 
74183 (Dec. 2, 2022); and Letter from Michael Simon, Chair Emeritus, 
CAT NMS Plan Operating Committee, to Vanessa Countryman, Secretary, 
Commission (Feb. 15, 2023).
    \59\ See FINRA April 2023 Letter at 5 (citing Letter to Vanessa 
Countryman, Secretary, Commission, from Lawrence Harris, Fred V. 
Keenan Chair in Finance, Professor of Finance and Business and 
Economics, U.S.C. Marshall School of Business, dated June 21, 2022).
    \60\ Id. Another commenter suggested a review of alternative 
approaches to funding, such as the extent to which CAT could be 
funded by Section 31 fees. See Letter to Vanessa Countryman, 
Secretary, Commission, from Kirsten Wegner, Chief Executive Officer, 
Modern Markets Initiative, dated July 13, 2023 (``MMI July 
Letter''), at 4.
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    One commenter stated that the Participants have not met their 
burden to demonstrate the proposed allocation is consistent with the 
Exchange Act fee standards and not arbitrary.\61\ The commenter stated 
that because FINRA is funded by Industry Members, Industry Members 
would pay over 80% of CAT costs since they must pay not only their own 
share but FINRA's as well; therefore, the Commission should disapprove 
the proposal.\62\ The commenter stated that the Proposed Amendment does 
not explain how allocating 80% of total CAT costs to the industry in 
perpetuity without a mechanism to limit the budget \63\ is consistent 
with the Exchange Act and guidance on SRO filings related to fees 
because the industry has no role in the governance, oversight or design 
of CAT and does not benefit from the CAT.\64\ Another commenter stated 
that Industry Members will bear significantly more costs than the 
Proposal suggests if the Participants decide to charge their members to 
fund their share of CAT fees.\65\ The commenter stated that ``[i]f the 
Participants were to do this, it would render the entire Funding Model 
meaningless, with Industry Members bearing 100% of CAT costs.'' \66\ 
Another commenter also stated that it was inappropriate to place 
responsibility for funding the CAT ``on industry members that do not 
stand to benefit from it.'' \67\
---------------------------------------------------------------------------

    \61\ See SIFMA May 2023 Letter at 6; SIFMA June 2023 Letter at 
1-2. The commenter also stated that the Proposed Amendment provides 
unsupported conclusory statements that it meets the requirements of 
the Exchange Act. See SIFMA June 2023 Letter at 2. See also id. at n 
11; FIA Letter at 2.
    \62\ See SIFMA May 2023 Letter at 2. See also SIFMA June 2022 
Letter at 1-2 (stating that the proposed cost allocation methodology 
is inconsistent with Exchange Act fee standards because most costs 
would be imposed on Industry Members).
    \63\ The commenter stated that the CAT annual budget increased 
over 30% in the last year. See SIFMA June 2023 Letter at 4. See also 
Virtu Letter at 4 (stating that the budget increase indicated that 
the Industry Members could be subject to ever-increasing fees with 
no say on the budget). See also FIA Letter at 3 (stating that 
``[w]ith little to no skin-in-the-game, the Participants will not be 
incentivized to control costs.''). See infra Section III.A.5.b 
(discussing budgeted CAT costs and comments suggesting a review 
mechanism to control costs).
    \64\ See SIFMA June 2023 Letter at 3, 4. The commenter stated 
that approving such a proposal would ``directly threaten[ ] 
efficiency, competition, and capital formation in U.S. securities 
markets.'' Id. at 4. The commenter also quoted a Commission release 
stating that the Participants are potentially conflicted in 
allocating CAT fees to themselves and the Industry Members. See 
Securities Exchange Act Release No. 89618 (Aug. 19, 2020), 85 FR 
65470, 65482 (Oct. 15, 2020). Another commenter stated that the 
allocation of 80% to the industry was unfair. See Virtu Letter at 4.
    \65\ See FIA Letter at 2.
    \66\ Id.
    \67\ See Virtu Letter at 2.
---------------------------------------------------------------------------

    One commenter stated that the Proposed Amendment does not 
demonstrate that it is equitable, as required by Section 6(b)(4),\68\ 
or rational, as required by the Administrative Procedure Act,\69\ to 
allocate two-thirds of CAT costs to Industry Members, stating that 
``there is no suggestion that Industry Members somehow receive 67% of 
the benefits from CAT.'' \70\ Furthermore, the commenter stated that 
the Proposed Amendment would result in an inequitable allocation to a 
small number of Industry Members.\71\
---------------------------------------------------------------------------

    \68\ 15 U.S.C. 78f(b)(4).
    \69\ 5 U.S.C. 551 et seq.
    \70\ See Citadel July Letter at 17.
    \71\ Id.
---------------------------------------------------------------------------

    The commenter also stated that the Proposed Amendment would result 
in the allocation of all of the costs to build and operate the CAT to 
Industry Members and would therefore be inconsistent with Section 
6(b)(4) to equitably allocate reasonable fees.\72\ The commenter stated 
that, in addition to the proposed allocation to Industry Members, 
FINRA's 11% cost allocation would be passed-on to Industry Members and 
that exchanges would also pass-on their 22% cost allocation.\73\ The 
commenter stated that, with FINRA's allocation, 78% of the costs to 
build and operate the CAT would be allocated to Industry Members under 
the Proposed Amendment.\74\ The commenter stated that 78% is the same 
amount allocated to Industry Members in a prior CAT funding model 
proposal from 2021, and stated that in the Proposed Amendment, the 
Operating Committee concedes that the 2021 allocation ``may have an 
adverse effect on competition, liquidity or other aspects of market 
structure,'' \75\ however the Proposed Amendment does not explain why 
using a different metric--executed share volume rather than message 
traffic--to create the same allocation would not result in similar 
consequences.\76\
---------------------------------------------------------------------------

    \72\ Id. at 1, 16, 22.
    \73\ Id. at 1, 21, 22.
    \74\ Id. at 21.
    \75\ Id.
    \76\ See Citadel July Letter at 21.
---------------------------------------------------------------------------

    Further, the commenter stated that Industry Members may also be 
required

[[Page 62632]]

to pay the exchange cost allocation,\77\ citing a statement in the 
Proposed Amendment that ``each Participant may determine to charge 
their members fees to fund their share of the CAT fees.'' \78\ The 
commenter stated that if exchanges choose to do this, then Industry 
Members would be responsible for 100% of CAT costs, which would 
``distort incentives and hinder the prioritization of critical cost-
control measures, as the firms governing CAT are not bearing any of the 
associated costs.'' \79\ The commenter requested that the Commission 
prohibit exchanges from passing-on their CAT costs.\80\ The commenter 
also stated that even after restructuring the funding model to base 
allocation on share volume instead of message traffic, as in prior 
funding model proposals, the allocation to exchanges stayed the same, 
arguing that the exchanges are unwilling to allocate themselves more 
than 22% of total costs.\81\ The commenter stated that the proposed 
allocation methodology is inconsistent with the Exchange Act because of 
the excessive percentage of total costs proposed to be allocated to 
Industry Members and the unfair method of allocating costs among 
Industry Members,\82\ stating, ``[t]he allocation methodology will have 
a direct and negative impact on market efficiency, competition, and 
capital formation, and the Commission must comprehensively assess those 
impacts before approving this filing.'' \83\
---------------------------------------------------------------------------

    \77\ Id. at 22. See also Citadel August Letter at 2.
    \78\ See Citadel July Letter at 22. See also Notice, supra note 
7, 88 FR at 17107. The commenter also stated that while the Proposed 
Amendment describes the funding model as ``neutral as to location 
and manner of execution,'' counterparties to off-exchange 
transactions would receive higher fees than on-exchange transactions 
if exchanges choose not to pass-on their cost allocation to Industry 
Members. See Citadel July Letter at 21. See also Notice, supra note 
7, 88 FR at 17087.
    \79\ Citadel July Letter at 22. See also id. at 16. See also 
Citadel August Letter at 2 (stating that an allocation of 100% of 
CAT costs to Industry Members cannot be lawful).
    \80\ Citadel July Letter at 22.
    \81\ Id. at 10.
    \82\ Id. at 15.
    \83\ Id.
---------------------------------------------------------------------------

    The commenter stated that the Proposed Amendment does not provide 
the percentage of total costs to build and operate the CAT that will be 
borne by Industry Members in practice.\84\ The commenter stated that it 
is necessary to determine the ultimate allocation of CAT costs to 
evaluate whether the proposed allocation is consistent with the 
Exchange Act, arguing that the statements made in support of the 
allocation were premised on the Participants being responsible for one-
third of total CAT costs, and that if this is untrue, ``the filing must 
be completely reconsidered, taking into account (a) the impact on 
market efficiency, competition and capital formation of allocating this 
magnitude of additional costs to Industry Members, (b) whether such a 
lopsided allocation is fair and equitable, and (c) the implications for 
CAT governance and budget control if the firms governing CAT do not 
have any skin-in-the-game.'' \85\
---------------------------------------------------------------------------

    \84\ See Citadel August Letter at 2.
    \85\ Id.
---------------------------------------------------------------------------

    One commenter stated that the Participants do not account for ``the 
time and expense Industry Members have devoted to developing and 
maintaining internal systems to be able to report the [sic] CAT, as 
well as the time and expense Industry Members have devoted to assisting 
the Operating Committee with its job of developing reporting 
specifications that allow the CAT to achieve its regulatory purpose'' 
in the proposed allocation \86\ and that ``this omission is a flaw with 
the Participants' decision to allocate two-thirds of the CAT costs to 
Industry Members and its inclusion would demonstrate that the 
Participants' Executed Share Model does not provide for the equitable 
allocation of reasonable fees.'' \87\
---------------------------------------------------------------------------

    \86\ SIFMA June 2022 Letter at 4. See also SIFMA January 2023 
Letter at 4.
    \87\ SIFMA June 2022 Letter at 4-5. See also SIFMA January 2023 
Letter at 5; Virtu Letter at 3.
---------------------------------------------------------------------------

    Similarly, one commenter stated that the allocation does not take 
into account fees currently paid by the industry and implementation 
costs incurred by Industry Members to comply with CAT reporting 
requirements.\88\ The commenter stated that Industry Members already 
provide funding for regulatory matters to exchanges through regulatory 
fees, membership fees, market data fees, and registration fees, and 
that these fees must be factored into any equitable or rational 
allocation of CAT costs.\89\ The commenter stated that although the 
Proposed Amendment argues that there is no precedent for regulatory 
fees to be determined based on the cost of compliance of a regulated 
entity, it is necessary to take into account all CAT-related costs 
including those already allocated to Industry Members to assess whether 
the Proposed Amendment is equitable.\90\
---------------------------------------------------------------------------

    \88\ See Citadel July Letter at 17. See also Virtu Letter at 2 
(noting that Industry Members ``already provide the Plan 
Participants with a very substantial level of funding through 
membership fees, registration and licensing fees, dedicated 
regulatory fees, and options regulatory fees'').
    \89\ See Citadel July Letter at 17 (further stating, ``Industry 
Members are already bearing nearly all of the total CAT-related 
costs, at a rate much higher than the Commission estimated in its 
approval of the 2016 CAT NMS Plan.'' Id. at 18).
    \90\ Id.
---------------------------------------------------------------------------

    Commenters also objected to statements made in the Proposed 
Amendment that the complexity of Industry Member business models 
contributes substantially to the costs of the CAT.\91\ One commenter 
stated that the proposed allocation of two-thirds of CAT costs to 
Industry Members is unfair, unreasonable and arbitrary because the 
Participants are equally responsible for the complexity of trading 
activity in the markets.\92\ The commenter disagreed with the 
Participants' argument that the allocation satisfies Exchange Act fee 
standards because Industry Members and the complexity of their business 
models drive the costs of the CAT, by stating that the examples of 
complexities provided were developed to address order types, activities 
and fee structures (such as the maker-taker fee structure) established 
by the Participant exchanges.\93\ The commenter stated that the 
Participants are just as responsible for such cost-driving complex 
trading activity in the equity and options markets as Industry Members 
due to the ``large number of equity and options exchanges established 
by the exchange families with fundamentally different execution models 
and order types.'' \94\ The commenter stated that the Participant 
exchanges have not analyzed how their own business decisions have 
resulted in the complexity of Industry Member order routing practices 
and CAT costs.\95\ Another commenter stated that the complexity 
arguments in the Proposed Amendment contradict statements from the 
Operating Committee that stringent performance and other requirements 
for processing CAT data are significant drivers of CAT costs,\96\ and 
that the complexity arguments suggest that costs should be allocated 
evenly among Industry Members, not just a small group of Industry 
Members based on volume.\97\
---------------------------------------------------------------------------

    \91\ See Notice, supra note 7, 88 FR at 17104.
    \92\ See SIFMA May 2023 Letter at 3. See also SIFMA January 2023 
Letter at 2, 3-4.
    \93\ See SIFMA May 2023 Letter at 6-7. See also SIFMA January 
2023 Letter at 3; Notice, supra note 7, 88 FR at 17104.
    \94\ SIFMA January 2023 Letter at 3.
    \95\ See SIFMA May 2023 Letter at 7.
    \96\ See Citadel July Letter at 17-18.
    \97\ Id. at 18.
---------------------------------------------------------------------------

    Commenters also disagreed with other justifications made in the 
Proposed Amendment for the proposed allocation; specifically, that 
there are more Industry Members than Participants and that Industry 
Members receive more in

[[Page 62633]]

revenue than the Participants.\98\ One commenter stated that these 
assertions are not relevant in demonstrating that the proposed 
allocation is fair and reasonable.\99\ The commenter stated that the 
Participants are justifying the allocation based on the ability to pay 
rather than cost generation, which the commenter believes is 
inconsistent ``with the Participant Exchanges' proposed approach . . . 
of allocating CAT costs based on approximate responsibility for 
generating them . . .'' and ``with the historical CAT decision to 
allocate costs to the parties responsible for generating them.'' \100\ 
The commenter suggested an alternative allocation that would equally 
split CAT costs between Participant exchanges and Industry Members, 
while FINRA would be subject only to a nominal regulatory user fee to 
access CAT Data.\101\ Another commenter stated that, while most 
Industry Members will pay little to no CAT costs, 20 Industry Members 
will be responsible for 75% of the costs allocated to Industry 
Members.\102\ The commenter said this would contradict the Proposed 
Amendment's arguments that there are more Industry Members than 
Participants and that Industry Members have greater financial resources 
than Participants because the Operating Committee would outnumber the 
Industry Members that would be paying the most in costs.\103\
---------------------------------------------------------------------------

    \98\ See Notice, supra note 7, 88 FR at 17104.
    \99\ See SIFMA May 2023 Letter at 7. See also SIFMA January 2023 
Letter at 4.
    \100\ See SIFMA May 2023 Letter at 7. The commenter cited to the 
funding principles in Section 11.2 of the CAT NMS Plan.
    \101\ See SIFMA January 2023 Letter at 4. See also SIFMA May 
2023 Letter at 8; SIFMA June 2022 Letter at 5; SIFMA October 2022 
Letter at 4. This commenter also suggested another alternative 
allocation in which costs would be allocated to those Participants 
and Industry Members most directly responsible for the costs. Under 
this alternative, Industry Members would be responsible for the cost 
associated with initial ingestion of the data into the CAT system. 
The commenter explained that Participants would be responsible for 
the costs associated with the stages after the data is initially 
ingested into the CAT system because the regulators directly control 
and benefit from these stages of the CAT system after ingestion. See 
SIFMA June 2022 Letter at 5-6.
    \102\ See Citadel July Letter at 17. The commenter also stated 
that the Proposed Amendment does not explain why it would be 
equitable to allocate 50% of total CAT costs to 20 Industry Members 
and 22% of total CAT costs to 24 exchanges. Id.
    \103\ Id.
---------------------------------------------------------------------------

    The commenter also stated that the Proposed Amendment lacks support 
for the proposed allocation.\104\ The commenter stated that the 
Operating Committee has not met its burden to demonstrate that the 
proposed allocation is consistent with the Exchange Act.\105\ The 
commenter also stated that the Proposed Amendment does not consider the 
impact of the proposed allocation to Industry Members on market 
efficiency, competition and capital formation, particularly with 
respect to the costs the industry will incur to build systems to pass-
through their CAT fees, the expected impact on volumes, the expected 
impact on retail investors, and the expected impact on market 
makers.\106\
---------------------------------------------------------------------------

    \104\ Id. at 13. See also Citadel August Letter at 2.
    \105\ See Citadel July Letter at 13.
    \106\ Id. at 2, 16, 19, 20. The commenter further stated that 
the Proposed Amendment is inconsistent with the Exchange Act because 
it cannot equitably allocate fees and will harm market efficiency, 
competition and capital formation. Id. at 16.
---------------------------------------------------------------------------

    The commenter suggested alternatives to the proposed allocation 
methodology.\107\ The commenter stated that Industry Members should not 
be allocated more than 50% of ongoing CAT costs (including FINRA's 
allocation) due to their lack of industry voting representation and 
because they already bear nearly all of the total CAT-related 
costs.\108\ The commenter also suggested that exchanges should be 
prohibited from passing-on their CAT cost allocation to market 
participants,\109\ and that the Participants consider allocating costs 
to the Commission ``to align incentives.'' \110\ The commenter 
recommended a consistent methodology for allocating costs to both 
Industry Members and exchanges.\111\ The commenter also recommended an 
allocation methodology that would ensure that ``a small group of firms 
are not disproportionately bearing costs given that CAT is designed to 
facilitate market-wide surveillance across all market participants,'' 
\112\ and would not inequitably allocate costs to specific market 
segments (such as ``retail trading activity in NMS stocks'').\113\ The 
commenter suggested that the approach could have ``(I) minimum and 
maximum fee levels, (II) appropriate calibrations for liquidity 
provision, (III) a volume component based on notional (instead of 
executed shares), and (IV) consideration of additional metrics that 
could achieve a more equitable outcome (e.g., broker-dealer capital).'' 
\114\
---------------------------------------------------------------------------

    \107\ Id. at 3, 30, 31. The commenter stated that the Commission 
must consider reasonable alternatives and that the proposal should 
be rejected and replaced by a proposal incorporating the commenter's 
recommendations. Id. at 30, 2.
    \108\ Id. at 3, 30, 31.
    \109\ See Citadel July Letter at 3, 30, 31.
    \110\ Id. at 3, 31. In response, CAT LLC stated that the 
Commission is not a party to the CAT NMS Plan, or subject to Rule 
608 of Regulation NMS or Section 19(b) of the Exchange Act. See 
Letter to Vanessa Countryman, Secretary, Commission, from Brandon 
Becker, CAT NMS Plan Operating Committee Chair, dated July 28, 2023 
(``CAT LLC July 2023 Response Letter''), at 31, n.144.
    \111\ See Citadel July Letter at 30-31.
    \112\ Id. at 30.
    \113\ Id. at 3, 30.
    \114\ See id. at 30. See also Citadel August Letter at 5.
---------------------------------------------------------------------------

    Commenters also raised concerns about statements in the Proposed 
Amendment that CAT costs would be passed on to investors.\115\ One 
commenter stated, ``[s]uch an assertion is inaccurate because it is 
almost certain that there will be scenarios faced by Industry Members 
in which they will not be able to figure out who was responsible for 
generating certain Historical CAT Costs.'' \116\ The commenter stated 
that such assertions would minimize the Participants' obligation to 
allocate fees consistent with Exchange Act fee standards and could 
result in the inequitable allocation of CAT fees to Industry Members 
under the mistaken belief that such fees would be passed down to 
investors.\117\ FINRA objected to statements in the Proposed Amendment 
that Industry Members can pass through to their customers their CAT 
cost allocation and additional costs resulting from an increase in 
FINRA fees.\118\ FINRA stated that ``[s]ummarily stating that investors 
can be made to bear the costs resulting from the Funding Model without 
a detailed description of and transparency into how these fees would be 
determined or passed on to customers is inadequate, and does not 
provide interested parties sufficient information to consider the costs 
and benefits related to the Fee Proposal.'' \119\ Another commenter 
expressed concern that CAT costs will be passed-through to investors 
directly or indirectly by affecting the transaction prices of equities, 
stating that this could negatively impact the investment returns of 
long-term investors (including retail investors).\120\ The commenter 
stated that the Participants have failed to analyze how passing-through 
CAT costs to investors is consistent with Exchange Act fee standards, 
and that the Commission has not fully considered

[[Page 62634]]

these economic effects on clients and other end investors.\121\
---------------------------------------------------------------------------

    \115\ See SIFMA May 2023 Letter at 8; FINRA April 2023 Letter at 
6-7; Citadel July Letter at 20; Citadel August Letter at 3; Letter 
to Vanessa Countryman, Secretary, Commission, from Lindsey Weber 
Keljo, Head--Asset Management Group, SIFMA, dated September 5, 2023 
(``SIFMA AMG Letter''). See also Virtu Letter at 4 (noting the 
inherent difficulties in implementing systems and processes to track 
and pass through fees to the appropriate client firms and stating 
that executing brokers would likely end up absorbing the fees 
themselves).
    \116\ See SIFMA May 2023 Letter at 8; see also Virtu Letter at 
4.
    \117\ See SIFMA May 2023 Letter at 8.
    \118\ See FINRA April 2023 Letter at 6-7.
    \119\ Id. at 7.
    \120\ See SIFMA AMG Letter at 2.
    \121\ Id. at 2, 3. The commenter stated that, ``[u]nder the 
Exchange Act, the Participants are required to demonstrate that the 
Proposed Amendment: (1) provides `for the equitable allocation of 
reasonable dues, fees, and other charges,' (2) is `not designed to 
permit unfair discrimination between customers, issuers, brokers or 
dealers' and (3) does not `impose any burden on competition not 
necessary or appropriate in furtherance of the purposes' of the 
Exchange Act.'' Id. at 1, n.4 (citing to Sections 6 and 15A of the 
Exchange Act and Rule 700(b)(3)(iii) of the Commission's Rules of 
Practice. 15 U.S.C. 78s; 15 U.S.C. 15o-3; 17 CFR 
201.700(b)(3)(iii)). Approval of the Proposed Amendment, however, is 
governed by Rule 608 of Regulation NMS. That rule requires the 
Commission to approve a proposed amendment to an effective national 
market system plan if it finds that the amendment is necessary or 
appropriate in the public interest, for the protection of investors 
and the maintenance of fair and orderly markets, to remove 
impediments to, and perfect the mechanisms of, a national market 
system, or otherwise in furtherance of the purposes of the Act. 17 
CFR 242.608(b)(2).
---------------------------------------------------------------------------

    One commenter stated that many of the largest Industry Members 
would be allocated CAT fees based on proprietary trading activity, so 
they would not be able to pass through their fees to investors.\122\ 
The commenter urged an analysis of proprietary executed volume compared 
to customer executed volume in order to evaluate how CAT costs will be 
allocated among Industry Members and whether the allocation methodology 
is fair, equitable and not unfairly discriminatory.\123\ The commenter 
also stated that the Proposed Amendment is inconsistent with Section 
6(b)(5) by imposing a new and increasing expense on investors, which 
would negatively impact liquidity and efficiency, and that the proposed 
allocation to Industry Members would disproportionately impact market 
makers (because 20 firms would have to pay most of the costs) and 
retail investors (due to their trading in sub-dollar NMS stocks that 
increase executed share volume), in violation of Section 6(b)(8).\124\
---------------------------------------------------------------------------

    \122\ See Citadel July Letter at 20. See also Citadel August 
Letter at 3.
    \123\ See Citadel August Letter at 3. The commenter said that 
such an analysis is feasible and should account for aggregate costs 
to be borne by affiliated entities, stating that this is required in 
Section 11.2(c) of the 2016 CAT NMS Plan. Id.
    \124\ See Citadel July Letter at 2. See also infra notes 260-
265.
---------------------------------------------------------------------------

    In response to the comment stating that the Participants had not 
analyzed a suggested Section 31-style approach to a funding model,\125\ 
CAT LLC stated that the CAT fee approach is similar to the Section 31 
fee approach in how an exchange would be obligated to pay a transaction 
fee based on transactions occurring on that exchange, and that FINRA 
would be obligated to pay a transaction fee based on transactions in 
the over-the-counter market.\126\ CAT LLC stated that the approaches 
are also similar because, in both, an exchange would be able to 
determine to pass the fee onto its members, as would FINRA.\127\ CAT 
LLC stated that if the Section 31 approach would comply with the 
Exchange Act, then the proposed CAT fee approach should also comply 
with the Exchange Act and CEBBs and CEBSs could determine whether to 
pass such fees onto their clients.\128\
---------------------------------------------------------------------------

    \125\ See FINRA April 2023 Letter at 5.
    \126\ See Letter to Vanessa Countryman, Secretary, Commission, 
from Brandon Becker, Chair, CAT NMS Plan Operating Committee, dated 
May 18, 2023 (``CAT LLC May 2023 Response Letter''), at 9.
    \127\ Id.
    \128\ Id.
---------------------------------------------------------------------------

    In response, FINRA stated that the CAT LLC May 2023 Response Letter 
misrepresented the commenter's letter by incorrectly stating that the 
commenter's letter recommended an approach similar to Section 31 
fees.\129\ FINRA clarified that it was noting that the Commission had 
received comments suggesting a model like the Section 31 fees, that the 
Participants had not ``meaningfully analyzed'' the suggested 
alternatives in the Proposed Amendment, and that the Commission should 
require the Participants to analyze the alternatives.\130\
---------------------------------------------------------------------------

    \129\ See FINRA May 2023 Letter at 3, n.8.
    \130\ Id.
---------------------------------------------------------------------------

    CAT LLC further responded to FINRA's objections to the use of the 
TAF as precedent for CAT fees--specifically, FINRA's statement that 
unlike the proposed CAT fees, the TAF recovers the costs of FINRA's 
regulatory activities, while the Proposed Amendment is designed to 
align with the costs to build, operate and administer the CAT.\131\ CAT 
LLC stated that there is no distinction between the two points raised 
by the commenter because CAT only has a regulatory purpose; therefore, 
costs to build, operate and administer the CAT are inherently 
regulatory costs.\132\ CAT LLC also noted that FINRA distinguished the 
TAF from the proposed CAT fees by describing the TAF as being used in 
combination with other funding mechanisms to support a funding 
framework, but CAT LLC stated that ``this does not change the general 
conclusion that a transaction-based fee complies with the Exchange 
Act.'' \133\
---------------------------------------------------------------------------

    \131\ See FINRA May 2023 Letter at 3.
    \132\ See CAT LLC July 2023 Response Letter at 35.
    \133\ Id.
---------------------------------------------------------------------------

    In response to a commenter that stated that there is no precedent 
for CAT fees to be allocated to Industry Members in perpetuity, and 
that the Exchange Act would not allow CAT LLC to require Industry 
Members to fund unlimited costs in perpetuity,\134\ CAT LLC stated that 
the proposed allocation would not require Industry Members to fund all 
costs since it would divide CAT costs such that one-third would be paid 
each by the Participant, CEBB and CEBS in a transaction.\135\ 
Furthermore, CAT LLC stated that fees would not be paid in perpetuity, 
as the Fee Rate set by the Operating Committee at the beginning of each 
year would be based on reasonably budgeted CAT costs and projected 
total executed equivalent share volume for the year and would be 
adjusted mid-year, and that to implement the Fee Rates, the 
Participants would need to file fee filings pursuant to Rule 19b-4 with 
the Commission that must be consistent with the Exchange Act and allow 
the public the opportunity to comment on the fees.\136\ CAT LLC added 
that the Executed Share Model would operate similarly to other fees 
that the Commission has determined are consistent with the Exchange 
Act, such as Participants' sales value fees related to Section 31, the 
TAF and the options regulatory fee, and that the comment did not 
recognize that Industry Members can choose to pass-through CAT fees to 
their customers like they do the Section 31-related sales value 
fees.\137\
---------------------------------------------------------------------------

    \134\ See Citadel July Letter at 27.
    \135\ See CAT LLC July 2023 Response Letter at 14.
    \136\ Id.
    \137\ Id.
---------------------------------------------------------------------------

    In response to comments that objected to the proposed allocation to 
Industry Members because Industry Members would not benefit from the 
CAT,\138\ CAT LLC stated allocating costs based on who benefits from 
the CAT is ``not appropriate or practical.'' \139\ CAT LLC stated that 
the CAT is intended to benefit all market participants, explaining how 
it would benefit Industry Members, and stated that it would be 
``impractical to determine a model that allocates a measurable amount 
of benefit that each market participant receives from the CAT.'' \140\ 
In response to a commenter that suggested that Industry Members should 
not be allocated any ``costs for matters that primarily benefit the CAT 
Operating Committee or the SROs,'' \141\ and a commenter that stated 
that the industry does not benefit from the CAT,\142\ CAT LLC disagreed 
that Industry Members do not benefit from the CAT because CAT is 
critical for the

[[Page 62635]]

protection of investors and because CAT supports fair and efficient 
markets.\143\ CAT LLC also stated that it was not ``reasonable or 
practical to attempt to parse CAT costs by who `primarily benefits' 
from those costs.'' \144\
---------------------------------------------------------------------------

    \138\ See Citadel July Letter at 17; Virtu Letter at 2.
    \139\ CAT LLC July 2023 Response Letter at 10.
    \140\ Id. at 11.
    \141\ Citadel July Letter at 32.
    \142\ See Virtu Letter at 4.
    \143\ See CAT LLC July 2023 Response Letter at 13.
    \144\ Id. at 12. See also id. at 13.
---------------------------------------------------------------------------

    In response to comments that state that Industry Members could bear 
100% of CAT costs if Participants decide to pass-through their costs to 
them,\145\ CAT LLC stated that Industry Members can pass through their 
own CAT fees to their customers, like broker-dealers do for 
transaction-based fees.\146\ CAT LLC stated that this may result in 
Industry Members not having any funding burden if they decide to 
entirely pass-through their allocation to investors.\147\ In response 
to commenters that requested that Participant be prohibited from 
passing-on their CAT costs to their members,\148\ CAT LLC stated that 
Participants are permitted by the Exchange Act to charge their members 
fees to fund the Participants' share of CAT fees, as long as they 
submit fee filings that demonstrate that any proposed fee is consistent 
with the Exchange Act.\149\
---------------------------------------------------------------------------

    \145\ See Citadel July Letter at 16, 22; FIA Letter at 2.
    \146\ See CAT LLC July 2023 Response Letter at 8.
    \147\ Id.
    \148\ See Citadel July Letter at 3, 22, 30; FIA Letter at 2-3.
    \149\ See CAT LLC July 2023 Response Letter at 9.
---------------------------------------------------------------------------

    In response to comments objecting to the proposed allocation to 
Industry Members for not taking into account regulatory fees currently 
paid by Industry Members,\150\ CAT LLC stated that the Proposed 
Amendment is intended to assess fees ``directly associated with the 
costs of establishing and maintaining the CAT, and not unrelated SRO 
services.'' \151\
---------------------------------------------------------------------------

    \150\ See Citadel July Letter at 17; Virtu Letter at 2. CAT LLC 
also objected to one commenter's description of the CAT as an 
exchange ``revenue generator,'' stating that CAT LLC is a business 
league under Section 501(c)(6) of the Internal Revenue Code, and 
that enforcement activity obtains restitution for investors and 
deters future misconduct rather than generating revenue. See CAT LLC 
July 2023 Response Letter at 13-14 (responding to Citadel July 
Letter at 17).
    \151\ CAT LLC July 2023 Response Letter at 13.
---------------------------------------------------------------------------

    In response to comments on whether Participants' models are equally 
to blame for the complexity of the markets,\152\ CAT LLC stated that 
its analysis of the complexity of the industry's business models is 
based on the effects of those models on the costs of the CAT, which it 
stated are more profound than those of Participants, not on complexity 
of the market in general.\153\ CAT LLC explained that the complexity of 
the Industry Members' business models results in significant data 
processing and storage costs, which Participants do not contribute to 
as they do not originate market activity or orders.\154\ CAT LLC 
explained that (1) the complexity and diversity of Industry Members' 
business models and order handling practices require processing and 
storage of hundreds of reporting scenarios for Industry Members, 
resulting in significant data processing and storage costs; \155\ (2) 
Industry Members have more late data and corrections than Participants, 
resulting in significant linker costs; \156\ and (3) Industry Members 
have customers, which results in CAT costs related to customer account 
information (FDID, CCID and CAIS) and customer investment 
strategies.\157\ CAT LLC also stated that Participants would pay the 
same amount as the CEBBs and CEBSs in each transaction.\158\ In 
response to one commenter that stated that Industry Members implemented 
complex routing strategies to optimize exchange fees and rebates 
because exchange business decisions resulted in these and other 
exchange fee structures,\159\ CAT LLC stated that the commenter did not 
demonstrate a causal connection between exchange fee structures and CAT 
costs.\160\ CAT LLC stated that it was not involved in these Industry 
Member business decisions and a substantial amount of CAT costs result 
from such business decisions.\161\ CAT LLC also stated that Participant 
activity does not contribute as much to CAT costs as complex Industry 
Member activity.\162\
---------------------------------------------------------------------------

    \152\ See SIFMA May 2023 Letter at 3; 6-7. See also SIFMA 
January 2023 Letter at 2, 3-4.
    \153\ See CAT LLC May 2023 Response Letter at 6; CAT LLC July 
2023 Response Letter at 6.
    \154\ See CAT LLC May 2023 Response Letter at 7; CAT LLC July 
2023 Response Letter at 7.
    \155\ See CAT LLC July 2023 Response Letter at 7.
    \156\ Id.
    \157\ Id.
    \158\ Id. at 6.
    \159\ See SIFMA May 2023 Letter at 7.
    \160\ See CAT LLC July 2023 Response Letter at 6.
    \161\ Id.
    \162\ Id.
---------------------------------------------------------------------------

    CAT LLC also disagreed with one commenter's dismissal of CAT LLC's 
consideration of Industry Members' relative ability to pay,\163\ 
stating that the Exchange Act specifically requires that the fees be 
fair and reasonable, which necessitates consideration of the relative 
ability to pay.\164\ CAT LLC stated that fairness issues require the 
Participants to consider the greater financial resources of Industry 
Members in the creation of a funding model. CAT LLC also stated that 
the commenter's position runs contrary to its comments that an Industry 
Member's ability to pay is an important consideration in the context of 
CAT fees.\165\
---------------------------------------------------------------------------

    \163\ See SIFMA May 2023 Letter at 7. See also SIFMA January 
2023 Letter at 4.
    \164\ See CAT LLC May 2023 Response Letter at 7; CAT LLC July 
2023 Response Letter at 7.
    \165\ See CAT LLC July 2023 Response Letter at 7-8.
---------------------------------------------------------------------------

    Additionally, CAT LLC objected to the commenter's statement that 
the proposed allocation is ``inconsistent with the historical CAT 
decision to allocate costs to the parties responsible for generating 
them.'' \166\ CAT LLC stated that, while the CAT NMS Plan does not 
require CAT costs to be allocated to parties responsible for generating 
such costs, the proposed allocation addresses cost burden on the CAT by 
(i) taking into account the impact of Industry Member activity on CAT 
costs, and (ii) using trading activity, which CAT LLC believes is a 
``reasonable proxy for cost burden on the CAT,'' \167\ as the metric 
for cost allocation.\168\ CAT LLC also stated that there are other 
examples of trading activity-based fees so the funding model would not 
be novel or unique.\169\
---------------------------------------------------------------------------

    \166\ See CAT LLC May 2023 Response Letter at 7; CAT LLC July 
2023 Response Letter at 8; SIFMA May 2023 Letter at 7.
    \167\ See CAT LLC May 2023 Response Letter at 7; CAT LLC July 
2023 Response Letter at 8.
    \168\ See CAT LLC May 2023 Response Letter at 7; CAT LLC July 
2023 Response Letter at 8.
    \169\ See CAT LLC July 2023 Response Letter at 8.
---------------------------------------------------------------------------

    Additionally, CAT LLC responded to the commenter's suggested 
alternative proposal that would equally allocate CAT costs to 
Participant exchanges and Industry Members, stating that the commenter 
did not explain why the alternative would satisfy the Exchange Act 
standards, and noting that CAT LLC had previously considered such an 
allocation but believed that it would not result in a fair and 
equitable allocation due to the greater number of Industry Members than 
Participants, the greater financial resources of Industry Members, and 
the failure of the suggested allocation to take into account how the 
complexity of Industry Member business models contributes substantially 
to CAT costs.\170\
---------------------------------------------------------------------------

    \170\ See CAT LLC May 2023 Response Letter at 7.
---------------------------------------------------------------------------

    In response, the commenter stated that the CAT LLC Response Letter 
did not meaningfully address the concerns it raised about the 
allocation of CAT costs between Participants and Industry Members.\171\ 
CAT LLC further responded, stating that it has responded to the 
commenter's comments several times and that just because CAT LLC did 
not adopt the commenter's viewpoints does not mean that CAT LLC

[[Page 62636]]

did not consider or respond to the commenter's comments.\172\
---------------------------------------------------------------------------

    \171\ See SIFMA June 2023 Letter at 2.
    \172\ See CAT LLC July 2023 Response Letter at 27.
---------------------------------------------------------------------------

    In response to a commenter that recommended allocating no more than 
50% of CAT costs to Industry Members, including the FINRA 
allocation,\173\ CAT LLC stated that the commenter did not offer a 
reasoned basis why such an allocation would be consistent with the 
Exchange Act.\174\ CAT LLC also stated that such an allocation would 
raise fairness concerns because, as compared to Participants, Industry 
Members have greater financial resources, and their complex business 
models ``contribute substantially to the costs of the CAT.'' \175\ 
Furthermore, in response to the commenter's other suggested allocation 
methodology which the commenter believed would ensure that a small 
group of firms and specific market segments would not be subject to 
inequitable cost burdens,\176\ CAT LLC stated that the commenter did 
not explain how the suggested methodology would fit into a funding 
model or how such a funding model would be consistent with the Exchange 
Act.\177\ CAT LLC stated that it evaluated various other funding models 
over the past seven years and concluded that ``the Executed Share Model 
provides a variety of advantages in comparison to the alternatives, and 
satisfies the requirements of the Exchange Act. . .'' \178\
---------------------------------------------------------------------------

    \173\ See Citadel July Letter at 31.
    \174\ See CAT LLC July 2023 Response Letter at 10.
    \175\ Id.
    \176\ See Citadel July Letter at 30.
    \177\ See CAT LLC July 2023 Response Letter at 10.
    \178\ Id. at 11-12.
---------------------------------------------------------------------------

    In response, the commenter stated that its suggestions, which 
included minimum and maximum fee levels, calibrations for liquidity 
provision, and consideration of additional metrics,\179\ were included 
in prior funding model proposals.\180\ The commenter stated that the 
CAT Operating Committee should explain why it changed its position on 
``the importance of these elements as part of a fair and equitable 
funding proposal that is consistent with the Exchange Act.'' \181\
---------------------------------------------------------------------------

    \179\ See Citadel August Letter at 5.
    \180\ Id. (citing the minimum and maximum fees and market making 
discounts proposed in a funding model proposal from the CAT 
Operating Committee that was filed in 2021. See Securities Exchange 
Act Release No. 91555 (Apr. 14, 2021), 86 FR 21050 (Apr. 21, 2021)).
    \181\ Id.
---------------------------------------------------------------------------

    The Executed Share Model reflects a reasonable approach to funding 
the building and operation of the CAT.\182\ The CAT NMS Plan requires 
both Participants \183\ and Industry Members (which would include CAT 
Executing Brokers) to fund the CAT.\184\ The costs of CAT therefore 
must be allocated in some fashion between Participants and Industry 
Members, and how to do so is a question of judgment for which there may 
be multiple reasonable approaches. CAT LLC has proposed to allocate CAT 
fees equitably among the three parties who have primary roles related 
to the transaction: the buyer, seller, and market regulator. In 
response to one commenter that stated that the proposed allocation 
methodology is inconsistent with the Exchange Act because of an 
excessive percentage of total costs proposed to be allocated to 
Industry Members and an unfair method of allocating costs among 
Industry Members,\185\ the Commission believes that the proposed 
allocation is reasonable as discussed below.\186\
---------------------------------------------------------------------------

    \182\ See 17 CFR 242.608(b)(2).
    \183\ The CAT NMS Plan requires Execution Venues and Industry 
Members to fund the CAT. The definition of ``Execution Venue'' 
includes Participants. See supra note 15.
    \184\ See CAT NMS Plan, supra note 2, at Section 11.1(b), 
11.3(a) and (b). Section 11.1(b) of the CAT NMS Plan authorizes the 
Operating Committee to establish fees for Execution Venues (which 
include Participants) and Industry Members to fund the CAT and 
Sections 11.3(a) and (b) of the CAT NMS Plan set forth how these 
fees would be calculated. See also Rule 613(a)(1)(vii)(D) discussing 
how the CAT NMS Plan shall discuss the proposed allocation of 
estimated costs among the plan sponsors, and between the plan 
sponsors and members of the plan sponsors. 17 CFR 
242.613(a)(1)(vii)(D).
    \185\ See Citadel July Letter at 15.
    \186\ See infra notes 189-201 and accompanying text.
---------------------------------------------------------------------------

    While a commenter said the Proposed Amendment did not justify why 
the TAF, options regulatory fee, and Section 31 fees should be used as 
a model in the context of the Executed Share Model,\187\ CAT was 
created to serve regulatory purposes. Moreover, CAT Data can only be 
used by SROs and the Commission for regulatory and surveillance 
purposes.\188\ Therefore, the costs incurred by the Participants to 
build, operate and administer the CAT similarly are regulatory costs, 
which here the Participants are seeking to recover through the CAT 
fees.
---------------------------------------------------------------------------

    \187\ See FINRA June 2022 Letter at 4; FINRA April 2023 Letter 
at 8.
    \188\ See 17 CFR 242.613(e)(4)(i)(A); CAT NMS Plan Sections 
6.5(c) and 6.5(g) and Appendix D, Section 8.1.
---------------------------------------------------------------------------

    Commenters expressed concerns that the Participants may impose fees 
on their members to recoup costs relating to CAT, making Industry 
Members responsible for CAT funding costs beyond those to which they 
will be directly assessed pursuant to the Executed Share Model,\189\ 
that CAT costs will be passed-through to investors and that this aspect 
of the Proposed Amendment lacks information needed to demonstrate that 
it meets the approval standard and to allow the Commission and other 
interested parties to consider the resulting economic effects.\190\ In 
response to the comments, the Commission acknowledges the concerns but 
also emphasizes that, as discussed above, the CAT provides important 
benefits in facilitating effective market surveillance and the Exchange 
Act expressly contemplates the ability of the Participants to recoup 
their costs to fulfill their statutory obligations under the Exchange 
Act.\191\ To that end, the CAT NMS Plan expressly contemplates the 
allocation of the costs associated with operating the CAT among the 
Participants and the Industry Members. The use of the Executed Share 
Model is a reasonable method, among a number of potential approaches to 
do so.
---------------------------------------------------------------------------

    \189\ See SIFMA May 2023 Letter at 2; Citadel July Letter at 16, 
17, 21, 22; Citadel August Letter at 2.
    \190\ See SIFMA AMG Letter at 2; FINRA April 2023 Letter at 6-7.
    \191\ Sections 6(b)(1) and 15A(b)(2) of the Exchange Act require 
that a national securities exchange or national securities 
association have the capacity to be able to carry out the purposes 
of the Exchange Act, the rules and regulations thereunder, and the 
rules of the exchange or association. 15 U.S.C. 78f(b)(1); 15 U.S.C. 
78o-3(b)(2).
---------------------------------------------------------------------------

    The Commission recognizes that these operational costs may be 
passed on in other ways, including by both the Participants and 
Industry Members, who each may elect to pass on such operational costs 
as fees to customers indirectly through their charges for services to 
customers. That would be true regardless of how the Proposed Amendment 
chose to set the initial allocation. Even if the Participants decide to 
pass-through the costs of CAT to Industry Members, however, in our 
view, the rule filing process under Section 19(b) and Rule 19b-4 will 
still incentivize the Participants to control costs. Any effort to 
pass-through costs will be subject to that process and, if the 
Participants fail to control costs, their ability to demonstrate that a 
proposed fee is reasonable and consistent with the Exchange Act may be 
compromised. After the Participants file their proposed rule changes 
relating to fees with the Commission, those proposed rule changes are 
published by the Commission and there is an opportunity for public 
comment.\192\ Although the proposed rule changes could likely take 
effect upon filing,\193\ the Commission

[[Page 62637]]

can temporarily suspend immediately effective rule changes if such 
action is necessary or appropriate in the public interest, for the 
protection of investors, or otherwise in furtherance of the purposes of 
the Exchange Act.\194\ If the Commission takes such action, the 
Commission will institute proceedings under Section 19(b)(2)(B) to 
determine whether the proposed rule changes should be approved or 
disapproved.\195\ Those fees, like any fees the Participants collect 
from their members to fund their SRO responsibilities in market and 
member regulation, must be consistent with applicable statutory 
standards under the Exchange Act, including being reasonable, equitable 
and not unfairly discriminatory.\196\ Additionally, as stated by CAT 
LLC, Industry Members may be able to offset fees that FINRA assesses 
them by passing their CAT fees through to their customers,\197\ and as 
discussed further below, the Commission believes that the additional 
costs borne by investors are likely small relative to current 
transaction costs.\198\ The Commission recognizes that not all Industry 
Members currently pass through fees and cannot determine in advance the 
extent to which Industry Members can or will pass-through their CAT 
fees to investors or would determine to do so in the future. But we 
believe that many are able to and that at least some will do so. For 
all of these reasons, contrary to the view of some commenters,\199\ the 
Commission does not believe that the inability to determine the amount 
of the CAT costs that will be passed along to investors precludes a 
finding that the allocation model set forth in the Proposed Amendment 
meets the approval standard.
---------------------------------------------------------------------------

    \192\ 15 U.S.C. 78s(b).
    \193\ 15 U.S.C. 78s(b)(3)(A); 17 CFR 240.19b-4(f)(2). Pursuant 
to Exchange Act Rule 19b-4, a proposed rule change may take effect 
upon filing with the Commission pursuant to Section 19(b)(3)(A) of 
the Exchange Act if properly designated by the self-regulatory 
organization as: (1) constituting a stated policy, practice, or 
interpretation with respect to the meaning, administration, or 
enforcement of an existing rule; (2) establishing or changing a due, 
fee, or other charge applicable only to a member; (3) concerned 
solely with the administration of the self-regulatory organization.
    \194\ 15 U.S.C. 78s(b)(3)(C).
    \195\ 15 U.S.C. 78s(b)(2)(B).
    \196\ See Section 6(b)(4); Section 15A(b)(5); Section 6(b)(5); 
Section 15A(b)(6). 15 U.S.C. 78f(b)(4); 15 U.S.C. 78f(b)(6); 15 
U.S.C. 78o-3(b)(5); 15 U.S.C. 78o-3(b)(6). See also e.g., Schedule A 
to the By-Laws of FINRA, Section 1(a) (stating ``FINRA shall, in 
accordance with this section, collect member regulatory fees that 
are designed to recover the costs to FINRA of the supervision and 
regulation of members, including performing examinations, financial 
monitoring, and policy, rulemaking, interpretive, and enforcement 
activities'').
    \197\ See Notice, supra note 7, 88 FR at 17108; see also CAT LLC 
July Response Letter at 8-9; cf. SIFMA May 2023 Letter at 8; Citadel 
July Letter at 20.
    \198\ Any efforts to recoup CAT costs will be subject to 
statutory and regulatory oversight as appropriate. Under the federal 
securities laws and FINRA rules, prices for securities and broker-
dealer compensation are required to be fair and reasonable, taking 
into consideration all relevant circumstances. See, e.g., Exchange 
Act Sections 10(b) and 15(c); FINRA Rules 2121 (Fair Prices and 
Commissions), 2122 (Charges for Services Performed), and 2341 
(Investment Company Securities). See also FINRA Rule 3221 (Non-Cash 
Compensation). Broker-dealers are also required to disclose the fees 
they charge related to a transaction pursuant to Exchange Act Rule 
10b-10. See 17 CFR 240.10b-10.
    \199\ See SIFMA AMG Letter at 2; FINRA April 2023 Letter at 6-7.
---------------------------------------------------------------------------

    In response to the commenter stating that proprietary trading firms 
cannot pass-through fees to investors and suggesting that an analysis 
of proprietary executed volume compared to customer executed volume is 
necessary to determine if the allocation is fair, equitable, and 
unfairly discriminatory,\200\ the Commission believes it is reasonable 
to charge executing brokers regardless of whether they are trading for 
their own account or for a customer's account. The Commission 
acknowledges that there is not a customer per se for proprietary trades 
and therefore, proprietary trading firms would not be able to pass-
through their CAT fees to customers. However, regardless of whether a 
firm trades for its own account or for a customer account, in both 
instances, the firm engages in trading activity to earn a profit. In 
the Commission's view, it is reasonable to allow a firm to incur CAT 
fees for its profit-making business activities, such as proprietary 
activity. The Commission recognizes that Industry Members may pass-
through CAT fees for customer executed volume but in the case of 
proprietary trades where a firm is trading for its own account, there 
is no customer to which the firm can pass-through fees, as the firm 
itself is the ultimate investor, and thus it is reasonable for the firm 
to be responsible for payment of CAT fees for those trades. Further, 
the Commission believes it is reasonable to allow a firm to incur CAT 
fees for its profit-making activity, which in this case is proprietary 
activity. CAT is a regulatory tool that will be used by the 
Participants and the Commission to oversee the activities for which 
Industry Members earn profits and therefore it is reasonable for fees 
to be charged for that profit-making activity, even if those fees 
cannot be passed on to customers.
---------------------------------------------------------------------------

    \200\ See Citadel July Letter at 20; Citadel August Letter at 3.
---------------------------------------------------------------------------

    While comments raised concerns that the industry would be allocated 
most of the CAT costs in perpetuity without a mechanism to limit the 
budget,\201\ there is a statutory process for notice and comment and 
Commission review of proposed rule changes relating to fees, under 
Section 19(b) and Rule 19b-4.\202\ In addition, the Proposed Amendment 
requires that the Fee Rate calculated by the Operating Committee twice 
per year be based on ``reasonably budgeted CAT costs'' \203\ and that 
such budgeted CAT costs be composed of ``all reasonable fees, costs and 
expenses reasonably budgeted to be incurred by or for the Company in 
connection with the development, implementation and operation of the 
CAT.'' \204\ The Operating Committee must demonstrate that their 
proposed budget and associated fees are reasonable, and the 
Participants must provide support for such reasonableness in their 
associated fee filings. If a Participant cannot demonstrate that their 
budgeted CAT costs are reasonable in a particular filing, following 
notice and public comment, then that would provide the Commission with 
grounds to suspend the filing and ultimately disapprove it, which 
should impose discipline or constraints on the fee setting process.
---------------------------------------------------------------------------

    \201\ See SIFMA June 2023 Letter at 3, 4; Citadel July Letter at 
2; FIA Letter at 2-5.
    \202\ See supra notes 192-196 and accompanying text.
    \203\ See proposed Section 11.3(a)(i)(A)(I) and proposed Section 
11.3(a)(i)(A)(II).
    \204\ See proposed Section 11.3(a)(i)(C).
---------------------------------------------------------------------------

    Further, the concerns expressed that the proposed allocation did 
not account for the costs already incurred by Industry Members to 
comply with the CAT or other fees paid by Industry Members to exchanges 
for other regulatory matters do not render that allocation 
unreasonable. Both Participants and Industry Members have incurred 
costs in adapting their operations to report to CAT as is required to 
achieve the benefits anticipated from the CAT. But the purpose of the 
funding model is to provide a framework for the recovery of a different 
set of costs--those incurred by the Participants' in developing and 
maintaining the CAT system. Section 11.1(c) of the CAT NMS Plan 
explicitly permits the Operating Committee to recover those costs, 
allowing it to ``take into account fees, costs and expenses . . . 
incurred by the Participants on behalf of the Company . . . and such 
fees, costs and expenses shall be fairly and reasonably shared among 
the Participants and Industry Members.'' \205\ The decision to exclude 
the costs of compliance from this funding model is thus a reasonable 
one.
---------------------------------------------------------------------------

    \205\ CAT NMS Plan, supra note 2, at Section 11.1(c).
---------------------------------------------------------------------------

    Further, the Commission does not base its finding with respect to 
the proposed allocation of costs between Participant and Industry 
Members on their respective responsibility for any

[[Page 62638]]

complexity in the markets. Regardless of the origin of that complexity, 
its existence contributes to the costs of CAT and the purpose of the 
funding model is to account for those current and future costs, not 
assess responsibility for the market structure. The Participants' 
decision to divide the costs evenly among the three parties who have 
primary roles related to the transaction is reasonable.
    As explained below, the Commission agrees with CAT LLC's statements 
that, ``[t]he Executed Share Model . . . reflects a reasonable effort 
to allocate costs based on the extent to which different CAT Reporters 
participate in and benefit from the equities and options markets,'' 
\206\ and is ``transparent, would be relatively easy to calculate and 
administer, and is designed not to have an impact on market activity 
because it is neutral as to the location and manner of execution.'' 
\207\ The Participants considered, and have previously proposed, 
alternative allocations and funding models.\208\ And the Commission 
acknowledges the alternative funding models and allocations suggested 
by commenters.\209\ Each of those alternatives, as well as those 
suggested by commenters, has relative strengths and weaknesses. 
Similarly, the alternatives suggested by a commenter,\210\ including 
maximum and minimum fees, appropriate calibrations for liquidity 
provision and consideration of additional provisions (e.g., broker-
dealer capital), have strengths and weaknesses. For example, imposing 
maximum and minimum fees would transfer costs from the largest members 
to the smallest members, distorting the economic incentives of the 
Executed Share Model. A similar distortion could arise to the extent 
market maker volume is discounted or otherwise calibrated or to the 
extent considering other metrics that are not necessarily correlated 
with the cost drivers of the CAT. Given the potential distortions that 
could occur with these alternatives, the Commission does not believe 
that the existence of those alternatives, or the remaining concerns 
identified by commenters individually or collectively, call into 
question the Proposed Amendment's satisfaction of the approval standard 
in Rule 608(b)(2),\211\ or otherwise warrant a departure from the 
policy choices made by the Participants.
---------------------------------------------------------------------------

    \206\ See Notice, supra note 7, 88 FR at 17087.
    \207\ Id.
    \208\ In the Proposed Amendment, CAT LLC stated that it 
considered but rejected a number of alternative approaches to the 
CAT funding model; specifically, an approach based on a CAT 
Reporter's cost burden on the CAT, a 50%-50% allocation of costs 
between Industry Members and Participant exchanges, a revenue-based 
funding model in which CAT Reporters would pay fees based on their 
revenue, a message traffic model in which both Industry Members and 
Participants would be assessed fees based on message traffic in the 
CAT, a sales value model in which fees would be calculated based on 
transaction sales models, an alternative allocation in which fees 
would only be allocated to the CEBS, and the 2018 and 2021 Fee 
Proposals, a model in which CAT LLC would allocate all costs among 
the Participants and permit each Participant to charge its own 
members as it deems appropriate, and a cost allocation based on a 
strict pro-rata distribution regardless of the type or size of CAT 
Reporters. Id. at 17105-06, 17117-19. See also CAT LLC May 2023 
Response Letter at 8, where CAT LLC responded that SIFMA did not 
offer a reasoned basis for why a 50-50 allocation would satisfy the 
standards set forth in the Exchange Act. While alternative models 
have been suggested and considered, the proposed Executed Share 
Model meets the approval standard in Rule 608(b)(2).
    \209\ See FINRA April 2023 Letter at 5; SIFMA January 2023 
Letter at 4. See also SIFMA May 2023 Letter at 8; SIFMA June 2022 
Letter at 5-6; SIFMA October 2022 Letter at 4; Citadel July Letter 
at 3, 30, 31, 32.
    \210\ See Citadel August Letter at 5.
    \211\ 17 CFR 242.608(b)(2).
---------------------------------------------------------------------------

3. Executed Equivalent Shares
    Under the Executed Share Model, a CAT fee would be charged with 
regard to each transaction in Eligible Securities \212\ as reported in 
CAT Data based on executed equivalent shares.\213\ A CAT Fee would be 
imposed with regard to transactions in Eligible Securities in the CAT 
Data regardless of whether the trade is executed on an exchange or 
otherwise than on an exchange.\214\
---------------------------------------------------------------------------

    \212\ The CAT NMS Plan defines an ``Eligible Security'' as 
including all NMS Securities and all OTC Equity Securities. See CAT 
NMS Plan, supra note 2, at Section 1.1. ``NMS Security'' is defined 
as ``any security or class of securities for which transaction 
reports are collected, processed, and made available pursuant to an 
effective transaction reporting plan, or an effective national 
market system plan for reporting transactions in Listed Options.'' 
Id. ``OTC Equity Security'' is defined by the CAT NMS Plan as ``any 
equity security, other than an NMS Security, subject to prompt last 
sale reporting rules of a registered national securities association 
and reported to one of such association's equity trade reporting 
facilities.'' Id.
    \213\ See Notice, supra note 7, 88 FR at 17086.
    \214\ Id. at 17093.
---------------------------------------------------------------------------

    Proposed Section 11.3(a)(i)(B) of the CAT NMS Plan describes how 
executed equivalent shares would be counted for purposes of calculating 
CAT fees. Specifically, the Executed Share Model uses the concept of 
executed equivalent shares as the transactions subject to a CAT Fee 
involve NMS Stocks, Listed Options and OTC Equity Securities, each of 
which have different trading characteristics.\215\ Proposed Section 
11.3(a)(i)(B) would require the shares to be reasonably counted for 
each type of Eligible Securities in the following manner:
---------------------------------------------------------------------------

    \215\ Id.
---------------------------------------------------------------------------

    NMS Stocks. Under the Executed Share Model, each executed share for 
a transaction in NMS Stocks would be counted as one executed equivalent 
share.\216\ Accordingly, proposed Section 11.3(a)(i)(B)(I) of the CAT 
NMS Plan would state that ``[f]or purposes of calculating CAT Fees, 
executed equivalent shares in a transaction in Eligible Securities will 
be reasonably counted as follows: (I) each executed share for a 
transaction in NMS Stocks will be counted as one executed equivalent 
share.'' \217\
---------------------------------------------------------------------------

    \216\ Id.
    \217\ Proposed Section 11.3(a)(i)(B)(I).
---------------------------------------------------------------------------

    Listed Options. Recognizing that Listed Options trade in contracts 
rather than shares, each executed contract for a transaction in Listed 
Options will be counted using the contract multiplier applicable to the 
specific Listed Option in the relevant transaction.\218\ Typically, a 
Listed Option contract represents 100 shares; however, it may also 
represent another designated number of shares.\219\
---------------------------------------------------------------------------

    \218\ See Notice, supra note 7, 88 FR at 17093.
    \219\ Id. See also proposed Section 11.3(a)(i)(B)(II).
---------------------------------------------------------------------------

    OTC Equity Securities. Similarly, in recognition of the different 
trading characteristics of OTC Equity Securities as compared to NMS 
Stocks, the Executed Share Model would discount the share volume of OTC 
Equity Securities when calculating CAT Fees.\220\ CAT LLC explained 
that many OTC Equity Securities are priced at less than one dollar--and 
a significant number are priced at less than one penny--per share and 
low-priced shares tend to trade in larger quantities.\221\ Accordingly, 
a disproportionately large number of shares are involved in 
transactions involving OTC Equity Securities versus NMS Stocks.\222\ 
Because the Executed Share Model would calculate CAT Fees based on 
executed share volume, CAT Reporters trading OTC Equity Securities 
would likely be subject to higher fees than their market activity may 
warrant.\223\ To address this potential concern, CAT LLC proposed that 
the Executed Share Model would count each executed share for a

[[Page 62639]]

transaction in OTC Equity Securities as 0.01 executed equivalent 
shares.\224\
---------------------------------------------------------------------------

    \220\ See Notice, supra note 7, 88 FR at 17093.
    \221\ Id.
    \222\ In an example provided by CAT LLC, based on data from 
2021, (1) the average price per executed share of OTC Equity 
Securities was $0.072 and the average price per executed share for 
NMS Stocks was $49.51; and (2) the average trade size for OTC Equity 
Securities was 63,474 and the average trade size for NMS Stocks was 
166 shares. Trades in OTC Equity Securities accounted for 77% of the 
number of all equity shares traded, but only 0.51% of the notional 
value of all equity shares traded. Id. at 17093, n.36.
    \223\ Id. at 17093.
    \224\ See proposed Section 11.3(a)(i)(B)(III).
---------------------------------------------------------------------------

a. Executed Equivalent Share Volume
    CAT LLC had represented that a disproportionately large number of 
shares are involved in transactions involving OTC Equity Securities 
versus NMS Stocks,\225\ that trades in OTC Equity Securities accounted 
for 77% of the number of all equity shares traded, but only 0.51% of 
the notional value of all equity shares traded,\226\ and that under the 
Executed Share Model, CAT Reporters trading OTC Equity Securities would 
likely be subject to higher fees than their market activity may 
warrant.\227\ CAT LLC also explained the analysis it undertook to 
determine to count each executed share for a transaction in OTC Equity 
Securities as 0.01 executed equivalent shares, stating the discount was 
the result of an analysis of several different metrics comparing the 
markets for OTC Equity Securities and NMS Stocks. CAT LLC stated that 
``(1) the ratio of total notional dollar value traded for OTC Equity 
Securities to OTC Equity Securities and NMS Stocks was 0.051%; (2) the 
ratio of total trades in OTC Equity Securities to total trades in OTC 
Equity Securities and NMS Stocks was 0.90%; and (3) the ratio of 
average share price per trade of OTC Equity Securities to average share 
price per trade for OTC Equity Securities and NMS Stocks was 0.065%.'' 
\228\ For ease of application and because the calculations involve 
averages, CAT LLC decided to round the metrics to 1%.\229\
---------------------------------------------------------------------------

    \225\ See Notice, supra note 7, 88 FR at 17093.
    \226\ Id. at 17093, n.36.
    \227\ Id. at 17093.
    \228\ Id.
    \229\ Id.
---------------------------------------------------------------------------

    In support of the use of executed equivalent shares to allocate 
costs under the Executed Share Model, CAT LLC explained that ``trading 
activity provides a reasonable proxy for cost burden on the CAT, and 
therefore is an appropriate metric for allocating CAT costs among CAT 
Reporters.'' \230\ CAT LLC stated that it is not feasible to determine 
the specific cost burden of each CAT Reporter on the CAT, explaining 
that ``[t]he computation of a specific CAT Reporter's burden on the CAT 
is complicated by the many inter-related factors that contribute to CAT 
costs, including message traffic, data processing, storage, the 
complexity of reporting requirements, reporting timelines, 
infrastructure, connectivity and more.'' \231\ CAT LLC added that 
increased trading activity correlates with an increased cost burden on 
the CAT and Industry Members are generally engaged in effecting 
transactions in the market, so executed share volume would be an 
appropriate metric for the allocation of CAT costs.\232\ CAT LLC stated 
that this conclusion is consistent with the Commission's prior 
recognition of the use of transaction volume to set regulatory 
fees.\233\ Additionally, CAT LLC stated that technology costs dominate 
all CAT costs, with compute costs comprising more than half of all 
technology costs, and ``[w]hile [compute costs] are related in part to 
message traffic, they are driven by the stringent performance 
timelines, data complexity and operational requirements in the CAT NMS 
Plan.'' \234\ This was one of the reasons CAT LLC decided to change 
from using message traffic to calculate CAT fees using executed 
equivalent share volume.\235\
---------------------------------------------------------------------------

    \230\ See Notice, supra note 7, 88 FR at 17103.
    \231\ Id. at 17105; see also id. at 17103.
    \232\ Id. at 17105.
    \233\ Id.
    \234\ Id.
    \235\ See Notice, supra note 7, 88 FR at 17105.
---------------------------------------------------------------------------

    Commenters questioned the support for the use of executed share 
volume instead of message traffic, which was previously proposed in 
prior funding models.\236\ FINRA stated that the Proposed Amendment 
does not explain why the use of executed share volume as the basis of 
the cost allocation methodology, instead of message traffic, is 
equitable.\237\ FINRA explained that in prior models, message traffic 
was the key proxy for cost generation used to align CAT fees with CAT 
costs, but the Executed Share Model would base its cost allocation 
methodology entirely on executed share volume.\238\ FINRA stated that 
the Participants' argument that executed share volume is related to 
cost generation is not enough to demonstrate that its use is reasonable 
and equitable.\239\
---------------------------------------------------------------------------

    \236\ See FINRA June 2022 Letter at 3, 4; Citadel July Letter at 
10.
    \237\ See FINRA June 2022 Letter at 3.
    \238\ Id.
    \239\ Id. at 4.
---------------------------------------------------------------------------

    Another commenter stated that the Operating Committee cannot 
explain why the proposed allocation to Industry Members is equitable, 
noting that it previously stated that charging Industry Members based 
on message traffic was the most equitable means of establishing 
fees.\240\ The commenter stated that allocating costs among Industry 
Members based on share volume is inconsistent with the Exchange 
Act.\241\ The commenter stated that there is no evidence to support the 
Operating Committee's assertion that trading activity is a reasonable 
proxy for cost burden on the CAT, explaining that the Operating 
Committee has stated before that CAT Data processing requirements and 
message traffic are significant drivers of CAT costs. The same 
commenter stated that, according to one Participant, options activity 
creates a greater cost burden than equities trading volume and that the 
Proposed Amendment does not accurately describe the sources of CAT's 
cost burdens.\242\ The commenter stated that the CAT Operating 
Committee must demonstrate how the proposed allocation would not 
unfairly discriminate against equities market participants and compare 
equities and options activity with respect to (i) their cost burden on 
the CAT and (ii) the allocation of CAT costs to Industry Members.\243\ 
The commenter stated that if the equities markets are subsidizing 
options activity, this could have broad impacts on equity market 
liquidity, competition and efficiency that must be assessed under the 
Exchange Act.\244\
---------------------------------------------------------------------------

    \240\ See Citadel July Letter at 10.
    \241\ Id. at 19.
    \242\ Id. at 18, 19. See also Citadel August Letter at 4.
    \243\ See Citadel August Letter at 4.
    \244\ Id.
---------------------------------------------------------------------------

    Further, the commenter stated that allocating costs based on volume 
would result in costs being mostly allocated to ``an extremely small 
group of broker-dealers,'' which would unduly burden competition.\245\ 
The commenter stated that the Proposed Amendment also lacks a 
discussion of the impact of this allocation on market competition, 
efficiency and liquidity, but that the Operating Committee recognized 
in the Proposed Amendment that prior proposals, where message traffic 
was a metric used for fee allocation, could impose an outsized 
financial impact on certain Industry Members.\246\
---------------------------------------------------------------------------

    \245\ Citadel July Letter at 19.
    \246\ Id. See also Citadel August Letter at 2-3.
---------------------------------------------------------------------------

    Additionally, FINRA objected to the statement in the Proposed 
Amendment that ``trading activity provides a reasonable proxy for cost 
burden on the CAT, and therefore is an appropriate metric for 
allocating CAT costs among CAT Reporters.'' \247\ The commenter stated 
that this statement is inconsistent with information that demonstrates 
that volume from FINRA's trade reporting facilities (``TRFs'') 
contributes ``a very small percentage of annual CAT compute and storage 
costs.'' \248\ FINRA stated, ``. . . despite the minimal data compute 
and storage costs for

[[Page 62640]]

transactions reported to the TRF, FINRA would be assessed an estimated 
34% of the total CAT costs to be borne amongst the 25 Participants, and 
more than all options exchanges combined,'' therefore it cannot support 
the Participants' assertion that trading activity is a reasonable proxy 
for cost burden.\249\ FINRA stated that the Proposed Amendment ``fails 
to provide for reasonable fees that are equitably allocated and not 
unfairly discriminatory, does not reflect a reasonable approach to 
allocating costs amongst the Participants, nor does it transparently or 
accurately present information regarding the true sources of cost 
burdens on the CAT.'' \250\
---------------------------------------------------------------------------

    \247\ FINRA May 2023 Letter at 2 (quoting Notice, supra note 7, 
88 FR at 17103.)
    \248\ FINRA May 2023 Letter at 2.
    \249\ Id. See also FINRA April 2023 Letter at 8.
    \250\ FINRA May 2023 Letter at 4.
---------------------------------------------------------------------------

    FINRA further stated that the Executed Share Model is inconsistent 
with the ``cost alignment'' funding principle in Section 11.2(b) of the 
CAT NMS Plan, which requires the Participants to seek to establish an 
allocation of costs that takes into account distinctions in the 
securities trading operations of Participants and Industry Members and 
their relative impact upon Company resources and operations.\251\ FINRA 
stated that ``the Proposal fails to establish a sufficient nexus 
between executed share volume and the technology burdens that generate 
CAT costs and fails to relate each reporter group's allocation to the 
burden that each reporter group imposes on CAT.'' \252\
---------------------------------------------------------------------------

    \251\ Id. See also FINRA April 2023 Letter at 7-9; Section 
11.2(b) of the CAT NMS Plan. The Proposed Amendment would amend 
Section 11.2(b). See proposed Section 11.2(b); see also infra 
Section III.A.8 (Additional Changes from Original Funding Model).
    \252\ FINRA June 2022 Letter at 4.
---------------------------------------------------------------------------

    In response to FINRA's comment raising concerns about the use of 
trading activity as a proxy for costs,\253\ CAT LLC stated that the 
Proposed Amendment would provide an appropriate approach for allocating 
CAT costs because Industry Member activity is generally for the purpose 
of effecting transactions, and trading activity impacts various factors 
driving CAT costs, such as storage, data processing and message 
traffic.\254\ CAT LLC also stated that the Exchange Act does not 
require fees to be directly correlated with the costs created by the 
person charged the fee.\255\ CAT LLC stated that it is difficult to 
determine the precise cost burden created by each CAT Reporter on the 
CAT, and believes trading activity is a reasonable proxy for cost 
burden on the CAT.\256\
---------------------------------------------------------------------------

    \253\ See FINRA May 2023 Letter at 2.
    \254\ See CAT LLC July 2023 Response Letter at 34.
    \255\ Id.
    \256\ Id.
---------------------------------------------------------------------------

    CAT LLC responded to the commenter's statement that the proposed 
allocation is inconsistent with the cost alignment principles of the 
CAT NMS Plan by noting that the Proposed Amendment incorporates the 
concept of cost burden in at least two ways.\257\ Specifically, CAT LLC 
stated that it does so because ``the allocation of CAT costs 
contemplates the effect of Industry Member activity on the cost of the 
CAT. . . and because trading activity provides a reasonable proxy for 
cost burden on the CAT, trading activity is an appropriate metric for 
allocating CAT costs among CAT Reporters.'' \258\ CAT LLC added that 
because there are other examples of trading activity-based fees, the 
Executed Share Model would not be novel or unique.\259\
---------------------------------------------------------------------------

    \257\ CAT LLC May 2023 Response Letter at 7.
    \258\ Id.
    \259\ Id.
---------------------------------------------------------------------------

    One commenter also stated that the Proposed Amendment made no 
adjustments for sub-dollar trading activity in NMS stocks, when 
adjustments were made to volume in OTC Equity Securities to adjust for 
the large number of shares transacted in sub-dollar securities.\260\ 
The commenter also stated that it is arbitrary, capricious, and 
unfairly discriminatory for the CAT Operating Committee to 
significantly adjust executed share volumes for sub-dollar OTC Equity 
Securities but not to do the same for sub-dollar NMS stocks, as retail 
investor transactions will be allocated a disproportionate percentage 
of total CAT costs simply due to the securities traded.\261\ The 
commenter stated that the CAT Operating Committee must explain why it 
proposes to treat these securities differently and analyze the impact 
on retail investors.\262\ The commenter also stated that since 
fractional shares would be rounded up to one share, the result would 
overstate volume.\263\ The commenter stated that the Proposed Amendment 
thus discriminates against Industry Members that handle retail orders 
because of the amount of retail activity in sub-dollar stocks and 
fractional share trading.\264\ The commenter stated that the Proposed 
Amendment does not explain why volume by shares was chosen over 
notional volume, or address its impact on specific Industry Members, 
investors, or overall market competition, efficiency and 
liquidity.\265\
---------------------------------------------------------------------------

    \260\ See Citadel July Letter at 20.
    \261\ See Citadel August Letter at 4-5.
    \262\ Id. at 5.
    \263\ See Citadel July Letter at 20.
    \264\ Id. See also Citadel August Letter at 4-5.
    \265\ See Citadel July Letter at 20. See also Citadel August 
Letter at 5.
---------------------------------------------------------------------------

    CAT LLC proposed to delete the requirement in existing Section 
11.2(b) of the CAT NMS Plan to take into account ``distinctions in the 
securities trading operations of Participants and Industry Members and 
their relative impact upon Company resources and operations'' in 
establishing the funding of the Company.\266\ CAT LLC explained that 
this requirement is related to using message traffic and market share 
in the calculation of CAT fees, as message traffic and market share 
were metrics related to the impact of a CAT Reporter on the Company's 
resources and operations.\267\ CAT LLC explained that the requirement 
is no longer relevant because the proposed Executed Share Model uses 
the executed equivalent shares metric instead of message traffic and 
market share.\268\
---------------------------------------------------------------------------

    \266\ See proposed Section 11.2(b).
    \267\ See Notice, supra note 7, 88 FR at 17099.
    \268\ Id.
---------------------------------------------------------------------------

    With respect to the deletion in Section 11.2(b) of the requirement 
that, when establishing the funding of the CAT, the Operating Committee 
must take into account ``distinctions in the securities trading 
operations of Participants and Industry Members and their relative 
impact upon Company resources and operations,'' FINRA stated that the 
Participants have proposed to delete the language in Section 11.2(b) 
because the proposed Executed Share Model is inconsistent with the 
language.\269\ FINRA stated that the Proposed Amendment ``seeks to 
amend the core funding principles to align with an unjustified 
allocation methodology.'' \270\ FINRA stated that any changes to the 
funding principles ``must be well-reasoned and transparent and must 
continue to support the achievement of a fair and equitable outcome.'' 
\271\
---------------------------------------------------------------------------

    \269\ See FINRA June 2022 Letter at 4; see also FINRA April 2023 
Letter at 7.
    \270\ FINRA June 2022 Letter at 4. The commenter states that the 
Executed Share Model instead places the greatest emphasis on the 
funding principle relating to the ``ease of billing and other 
administrative functions,'' favoring that principle over cost 
alignment. Id. at 5.
    \271\ Id.; FINRA April 2023 Letter at 8-9.
---------------------------------------------------------------------------

    In the Commission's view, the use of executed equivalent share 
volume as the basis of the proposed cost allocation methodology is 
reasonable and consistent with the approach taken by the funding 
principles of the CAT NMS Plan.\272\ The proposed use of executed 
equivalent shares would continue to incorporate the concept of cost

[[Page 62641]]

alignment because trading activity, as reflected through executed 
equivalent share volume, would, as CAT LLC explained, correlate with 
the cost burden on the CAT.\273\ It may not be possible to directly 
calculate each CAT Reporter's cost burden on the CAT due to the many 
factors impacting CAT costs, such as data processing, storage, 
reporting timelines and requirements, and connectivity. But executed 
equivalent share volume is a reasonable proxy for those costs because 
it is a result of trading activity, which CAT LLC explained impacts 
various CAT cost drivers, such as storage, data processing and message 
traffic.\274\ In addition, because the proposed use of executed 
equivalent share volume would preserve the cost alignment principle, 
while no longer relying on message traffic, the deletion of the 
requirement in Section 11.2(b) of the CAT NMS Plan that the Operating 
Committee, in allocating costs, take into account ``distinctions in the 
securities trading operations of Participants and Industry Members and 
their relative impact upon Company resources and operations'' \275\ is 
reasonable.
---------------------------------------------------------------------------

    \272\ See Section 11.2(b) of the CAT NMS Plan.
    \273\ CAT LLC May 2023 Response Letter at 7.
    \274\ Id. See also Notice, supra note 7, 88 FR at 17105; see 
also id. at 17103.
    \275\ See Notice, supra note 7, 88 FR at 17105; see also id. at 
17103.
---------------------------------------------------------------------------

    In response to the commenter that urged the CAT Operating Committee 
to demonstrate how the proposed allocation would not unfairly 
discriminate against equities market participants by subsidizing CAT 
costs related to options market activity,\276\ the Commission believes 
that subsidization of options market activity likely is reduced due to 
other CAT cost burdens, such as those relating to data processing (such 
as equity linkage processing, which the Commission understands is more 
complex than options order linkage processing, and thus more 
costly),\277\ imposed on the CAT by equity market activity. The 
Commission, however, does not believe the failure to eliminate the 
potential subsidization of options market activity (and any potential 
attendant impacts on liquidity, competition and efficiency) renders the 
Participants' Funding Model proposal inconsistent with the Exchange 
Act. The Commission does not believe it is possible for the 
Participants to predict with certainty how the magnitude of each driver 
of CAT costs will change over time. To the extent the other costs noted 
above exceed, for example, the subsidy accorded to options market 
participants when calculating their executed equivalent shares, there 
may be no subsidy or even a reverse subsidy from options to equities 
markets. When the relative magnitudes of these cost drivers change, the 
amount of any subsidy changes. In light of the potential for the cost 
drivers to change over time, the Commission believes that the 
Participants' proposal is reasonable.
---------------------------------------------------------------------------

    \276\ See Citadel August Letter at 4.
    \277\ See infra notes 1075-1082 and accompanying text.
---------------------------------------------------------------------------

    The Proposed Amendment's treatment of sub-dollar NMS stocks and 
fractional shares is appropriate. The Commission does not believe that 
the Participants' failure to discount sub-dollar NMS stocks renders the 
Proposed Amendment inconsistent with the Exchange Act. The Commission 
acknowledges one commenter's statement that retail investors could be 
allocated a disproportionate percentage of total CAT costs due to the 
lack of a discount for sub-penny NMS stocks.\278\ However, treating a 
subset of NMS stocks differently from NMS securities could introduce 
unnecessary complexity or administrative burdens to the extent an NMS 
stock price falls or rises above a dollar. It is therefore reasonable 
for the Proposed Amendment to treat all NMS stocks the same, even 
though certain sub-dollar NMS stocks and fractional shares might have 
characteristics similar to OTC Equity Securities. Additionally, in 
response to the commenter's statement that since fractional shares 
would be rounded up to one share, the result would overstate 
volume,\279\ the Commission notes that CAT fees will be based on the 
data contained in the transaction reports and transaction reports do 
not provide for fractional quantities; therefore, CAT fees cannot be 
calculated using fractional shares or fractional share components of 
executed orders at this time.\280\ CAT LLC stated that if FINRA's 
equity transaction reporting facilities or the exchanges report 
transactions in fractional shares in the future, then the calculation 
of CAT fees would also reflect fractional shares.\281\ In response to 
the comment that stated that the Proposed Amendment does not explain 
why volume by shares was chosen over notional volume,\282\ calculating 
the notional value of stock introduces additional complexity as the 
notional value would have to be calculated and would depend on the 
value of the execution or trade, whereas the number of executed shares 
is reported and, in the cases of options for example, is based on a 
known multiplier (1/100). While the Commission does not disagree that 
using executed notional shares may offer advantages and may lessen any 
discrimination, the Commission believes that the Proposed Amendment's 
use of executed shares is administratively easier, less prone to error, 
and thus for these reasons and the reasons set forth above,\283\ is a 
reasonable proxy for allocating the cost of the CAT.
---------------------------------------------------------------------------

    \278\ See Citadel August Letter at 4-5.
    \279\ See Citadel July Letter at 20.
    \280\ See Notice, supra note 7, 88 FR at 17089.
    \281\ Id. at 17089, n.23.
    \282\ See Citadel July Letter at 20. See also Citadel August 
Letter at 5.
    \283\ See supra notes 272-275 and accompanying text.
---------------------------------------------------------------------------

    The Commission also believes that CAT LLC's explanation that 
increased trading activity correlates with an increased cost burden on 
the CAT is reasonable and that executed share volume is a reasonable 
proxy for a CAT Reporter's cost burden on the CAT \284\ because 
increased trading activity impacts message traffic, but also data 
processing and storage costs.\285\ The Original Funding Model would 
have used message traffic and market share to assess CAT fees on 
Industry Members and Execution Venues, respectively.\286\ CAT LLC 
expressed its belief that the use of executed equivalent share volume 
would be an improvement on the Original Funding Model's use of message 
traffic,\287\ explaining that the use of executed equivalent share 
volume would result in fees tied to transactions (which CAT LLC stated 
is the ``traditional source of revenue for Industry Members'' \288\), 
that the resulting CAT fees would not adversely impact market makers, 
and that the Executed Share Model is simple to understand and to 
implement.\289\ CAT LLC stated that Industry Member revenue is often 
driven by transactions, but ``[b]ecause message traffic is separate 
from whether or not a transaction occurs, fees based on message traffic 
may not correlate with common revenue or fee models,'' \290\ which 
could negatively impact certain Industry Members in a significant 
way.\291\ CAT LLC stated that use of message traffic to calculate fees 
for Industry Members could adversely impact market makers because they

[[Page 62642]]

generally create high levels of message traffic.\292\ We agree with CAT 
LLC regarding the benefits of the Executed Share Model and the 
drawbacks of the Original Funding Model, and thus believe that the 
decision to replace the use of message traffic to calculate CAT fees 
with executed equivalent share volume in the Executed Share Model is 
reasonable.
---------------------------------------------------------------------------

    \284\ See Notice, supra note 7, 88 FR at 17105; id. at 17101-03.
    \285\ Id. at 17105.
    \286\ See CAT NMS Plan, supra note 2, at Section 11.3(a) and 
(b).
    \287\ See Notice, supra note 7, 88 FR at 17102-03. The Original 
Funding Model uses message traffic as the basis of Industry Member 
CAT fees. See CAT NMS Plan, supra note 2, at Section 11.3(b).
    \288\ Notice, supra note 7, 88 FR at 17103.
    \289\ Id.
    \290\ Id. at 17102.
    \291\ Id.
    \292\ Id. at 17103.
---------------------------------------------------------------------------

    The Commission acknowledges that executions do not take place on 
FINRA; however, the CAT NMS Plan already categorizes FINRA as an 
Execution Venue because it has trades reported by its members to its 
TRFs for reporting transactions effected otherwise than on an exchange. 
Thus, treatment of FINRA as an Execution Venue is not a change to the 
existing CAT NMS Plan.\293\ Additionally, this allocation of fees to 
FINRA is similar to how Section 31 fees are assessed on FINRA.\294\
---------------------------------------------------------------------------

    \293\ See CAT NMS Plan Approval Order, supra note 2, 81 FR at 
84793; CAT NMS Plan, supra note 2, at Section 1.1. (defining 
``Executing Venues'').
    \294\ 15 U.S.C. 78ee; Section 31 of the Securities Exchange Act 
requires each national securities exchange and national securities 
association to pay transaction fees to the Commission. Specifically, 
Section 31(c) requires each national securities association to pay 
to the Commission fees based on the aggregate dollar amount of 
covered sales transacted by or through any member of the association 
other than on an exchange. 15 U.S.C. 78ee(c). Section 31(a) permits 
the Commission to collect transaction fees and assessments designed 
to recover the costs to the Government of the annual appropriation 
to the Commission by Congress. 15 U.S.C. 78ee(a).
---------------------------------------------------------------------------

    Moreover, the Executed Share Model does not change the criteria 
used to charge Execution Venues (market share).\295\ While there are 
differences in how the CAT fees would be allocated among the 
Participants under the Executed Share Model and the existing Original 
Funding Model, under the Executed Funding Model, as in the Original 
Funding Model, the fees charged to Participants will continue to be 
based upon the level of market share of each Participant.\296\ The 
Original Funding Model approved by the Commission would have assessed 
CAT fees on Execution Venues (which would include the Participants) 
\297\ based on market share determined by the share volume for a 
national securities exchange and determined by reported share volume of 
trades for a national securities association (i.e., FINRA) that had 
trades reported by its members to its trade reporting facility or 
facilities for reporting transactions effected otherwise than on an 
exchange in NMS Stocks or OTC Equity Securities.\298\ Additionally, 
this allocation is similar to how Section 31 fees are assessed on the 
exchanges and FINRA. FINRA's allocation of CAT fees under the Executed 
Share Model will continue to be based on its off-exchange market share.
---------------------------------------------------------------------------

    \295\ See CAT NMS Plan Approval Order, supra note 2, 81 FR at 
84793-97; CAT NMS Plan, supra note 2, at Section 11.2, Section 11.3.
    \296\ Id.
    \297\ See supra note 15.
    \298\ See CAT NMS Plan, supra note 2, at Section 11.3(a)(i).
---------------------------------------------------------------------------

    The Commission recognizes that the proposed use of executed 
equivalent share volume is not a perfect proxy for CAT costs, but 
believes it is nonetheless a reasonable proxy. The costs of CAT are 
attributable to a number of factors, such as message traffic, storage, 
and data processing costs, and that for these reasons, the Commission 
understands that it is difficult to calculate each CAT Reporter's 
individual cost burden on the CAT. Additionally, there are other 
operational costs of the CAT that cannot be easily attributed to a 
particular CAT Reporter and that need to be funded, such as costs for 
CAT NMS Plan requirements related to intake capacity,\299\ data search 
tools \300\ and data security.\301\ Based on the breadth of CAT costs, 
it is not feasible to calculate the cost burden on CAT of each CAT 
Reporter. A reasonable proxy for CAT cost burden must therefore be 
used. As discussed above, the Commission believes the proposed use of 
executed equivalent share volume is a reasonable method of 
approximating the cost burden of CAT.\302\ Additionally, CAT LLC stated 
that the proposed Executed Share Model would not unfairly burden or 
favor a product or product type because the model would recognize the 
different types of securities by counting executed equivalent share 
volume differently for NMS Stocks, Listed Options and OTC Equity 
Securities.\303\ The proposed treatment of these different types of 
securities would result in the equitable allocation of reasonable CAT 
fees across these securities. The Executed Share Model would count each 
executed contract for a transaction in Listed Options using the 
contract multiplier applicable to the specific Listed Option in the 
relevant transaction,\304\ which is appropriate because a Listed Option 
contract typically represents 100 shares, or it could represent another 
designated number of shares, and since Listed Options trade in 
contracts instead of shares, they would need to be converted into 
shares for purposes of calculating the executed equivalent share volume 
of a transaction in Listed Options. For OTC Equity Securities, the 
Executed Share Model would count each executed share for a transaction 
in OTC Equity Securities as 0.01 executed equivalent shares,\305\ which 
is appropriate because CAT LLC represented that this amount was a 
result of an analysis it conducted of several different metrics 
comparing the markets for OTC Equity Securities and NMS Stocks, 
specifically total notional dollar value, total trades, and average 
share price per trade.\306\ Additionally, since transactions in OTC 
Equity Securities typically are priced below one dollar, or even one 
penny, and tend to trade in larger quantities, this treatment is 
appropriate to prevent CAT Reporters trading OTC Equity Securities from 
being assessed higher CAT fees than their activity would deserve.
---------------------------------------------------------------------------

    \299\ In the CAT NMS Plan Notice, the Commission said that it 
preliminarily believed that intake capacity level is likely to be a 
primary cost driver for the Central Repository. See Securities 
Exchange Act Release No. 77724 (Apr. 27, 2016), 81 FR 30614 (May 17, 
2016), 81 FR at 30770.
    \300\ See CAT NMS Plan, supra note 2, at Appendix C, Section 
8.1-8.2.
    \301\ Id. at Appendix D, Section 4.
    \302\ See supra notes 271-274 and accompanying text.
    \303\ See Notice, supra note 7, 88 FR at 17116.
    \304\ Id. at 17093. A Listed Option contract typically 
represents 100 shares, or it could represent another designated 
number of shares. Id.
    \305\ See proposed Section 11.3(a)(i)(B)(III).
    \306\ See supra notes 227-229 and accompanying text.
---------------------------------------------------------------------------

b. Options vs. Equities
    The equal allocation of Participant CAT fees to Participants, 
regardless of whether they are transacting in options or in equities, 
is reasonable. The Original Funding Model would have divided 
Participant CAT fees by Execution Venues that execute transactions (or 
in the case of a national securities association, has trades reported 
by its members to its trade reporting facility or facilities for 
reporting transactions effected otherwise than on an exchange) in NMS 
Stocks or OTC Equity Securities and by Execution Venues that execute 
transactions in Listed Options.\307\ The Executed Share Model instead 
assesses a CAT fee based purely on executed equivalent share 
volume.\308\ CAT LLC explained that the use of equivalent executed 
share volume is designed to

[[Page 62643]]

normalize options and equities in the calculation of fees, and to 
recognize and address the different trading characteristics of 
different types of securities by counting executed equivalent share 
volume differently for Listed Options and for equities.\309\ The use of 
executed equivalent share volume and, in particular, the different 
weights assigned to equities versus options, are designed to result in 
an equitable treatment of the equities and options markets. The 
proposed treatment of these different types of securities reasonably 
equalizes the CAT fees across these securities. The Executed Share 
Model would count each executed contract for a transaction in Listed 
Options using the contract multiplier applicable to the specific Listed 
Option in the relevant transaction,\310\ which is appropriate because 
one options contract typically represents 100 shares.
---------------------------------------------------------------------------

    \307\ See CAT NMS Plan, supra note 2, at Section 11.3(a)(i), 
(ii).
    \308\ The Executed Share Model would count executed equivalent 
share volume differently for NMS Stocks, OTC Equity Securities and 
Listed Options for purposes of calculating a CAT fee. CAT LLC 
explains that the proposed approach ``would not favor or unfairly 
burden any one type of product or product type.'' See Notice, supra 
note 7, at 17116. See also supra Section III.A.3.
    \309\ See Notice, supra note 7, 88 FR at 17108.
    \310\ Id. at 17093.
---------------------------------------------------------------------------

c. FINRA Allocation
    Under the Executed Share Model, because FINRA is the Participant 
primarily responsible for oversight of off-exchange securities trading 
activity,\311\ FINRA will likely have greater executed equivalent share 
volume than other Participants \312\ and thus will be responsible for a 
significant portion of total CAT fees. In the Proposed Amendment, CAT 
LLC stated that the size of FINRA's fee is calculated based on the 
activity in the over-the-counter market.\313\ CAT LLC stated that the 
executed equivalent share volume for over-the-counter trades in 
Eligible Securities in 2021 was 1,361,484,729,008 out of a total volume 
of 3,963,697,612,395 executed equivalent shares for trades in Eligible 
Securities.\314\ CAT LLC stated that approximately 34% of the executed 
equivalent share volume in Eligible Securities took place in the over-
the-counter market.\315\
---------------------------------------------------------------------------

    \311\ See Securities Exchange Act Release No. 95388 (July 29, 
2022), 87 FR 49930 (Aug. 12, 2022), at 49931 (stating that FINRA 
historically has overseen off-exchange securities trading activity 
and that ``the Exchange Act's statutory framework places SRO 
oversight responsibility with a [national securities association] 
for trading that occurs elsewhere than an exchange to which a broker 
or dealer belongs as a member.''), 49932 (stating that an exchange 
would primarily have SRO oversight responsibility of its members and 
their trading on the exchange, while SRO oversight of other trading 
activity, such as off-exchange trading, is primarily the 
responsibility of a national securities association).
    \312\ See Notice, supra note 7, 88 FR at 17107.
    \313\ Id.
    \314\ Id.
    \315\ Id.
---------------------------------------------------------------------------

    CAT LLC stated that the assessment of a CAT fee on FINRA in the 
same manner as the other Participants would not result in a burden on 
competition for FINRA or for Industry Members engaging in off-exchange 
activity.\316\ CAT LLC also stated that FINRA and the exchanges should 
not be evaluated differently based upon the potential for a particular 
Participant to recoup its CAT fees through charging fees to its members 
or through revenue-generating activity other than passing its fees 
through to its members.\317\ CAT LLC stated that each Participant, 
including FINRA, can choose to charge its members fees to fund the 
Participant's CAT fees.\318\ Additionally, CAT LLC stated that FINRA, 
just like the exchange Participants, has revenue sources other than 
membership fees,\319\ explaining that FINRA generates significant 
revenues via Regulatory Services Agreements (``RSAs'') with the 
exchanges, among other sources.\320\ According to CAT LLC, these other 
revenue sources may be used to pay CAT fees, and, if they are used, 
would not lead to an increase in fees for Industry Members.\321\
---------------------------------------------------------------------------

    \316\ Id.
    \317\ Id. See also CAT LLC May 2023 Response Letter at 9.
    \318\ See Notice, supra note 7, 88 FR at 17107.
    \319\ Id. at 17108.
    \320\ Id.
    \321\ Id.
---------------------------------------------------------------------------

    Certain commenters objected to the proposed allocation of 
Participant CAT fees to FINRA.\322\ A subset of these commenters 
objected to the allocation to FINRA of 34% of the total CAT costs \323\ 
to be borne by the Participants.\324\ FINRA stated that this amount was 
a ``disproportionate share of CAT costs,'' \325\ especially as FINRA 
does not operate a market,\326\ and that the Proposed Amendment would 
place an undue burden on FINRA.\327\ FINRA stated that its share was 
``more than double that of the next highest Participant and $4 million 
more than all option exchanges combined.'' \328\ FINRA also stated that 
its allocation would largely be based on transaction volume reported to 
the TRF; however, FINRA stated that TRF transactions generate fewer 
costs for the CAT,\329\ as opposed to options activity, but that only 
25% of total Participant CAT fees would be assessed for options 
activity, while the remaining 75% would be assessed for equities 
activity.\330\ FINRA stated that ``. . . FINRA would be assessed an 
estimated 34% of the total CAT costs to be borne amongst the 25 
Participants, and more than all options exchanges combined.'' \331\
---------------------------------------------------------------------------

    \322\ See FINRA May 2023 Letter; FINRA April 2023 Letter; FINRA 
June 2022 Letter; SIFMA May 2023 Letter; SIFMA June 2022 Letter; 
SIFMA October 2022 Letter. One of the commenters supported the 
points raised in the FINRA April 2023 Letter that stated that the 
Proposed Amendment would result in the inequitable allocation of 
fees and should be disapproved. See SIFMA May 2023 Letter at 2. 
Another commenter supported these points and stated that the fact 
that one of the biggest Participants was so strongly opposed to the 
plan was evidence that it should be disapproved. See Virtu Letter at 
3.
    \323\ One commenter stated that this estimate is based on 2021 
data and urged the Commission to require the Participants to amend 
the Proposed Amendment to include the 2022 data and fee allocation 
estimates, stating that the CAT budget has grown significantly from 
2021. See FINRA April 2023 Letter at 3, 4-5. In its response to 
comments, CAT LLC provided the Historical CAT Costs for 2022. The 
total operating expenses increased from $144,415,268 in 2021 to 
$181,107,294 for 2022. See Notice, supra note 7, 88 FR at 17111; CAT 
LLC May 2023 Response Letter at 13.
    \324\ See FINRA May 2023 Letter at 2; FINRA April 2023 Letter at 
3; SIFMA May 2023 Letter at 2.
    \325\ FINRA April 2023 Letter at 3.
    \326\ Id.
    \327\ See FINRA June 2022 Letter at 6.
    \328\ FINRA April 2023 Letter at 4; see also FINRA June 2022 
Letter at 5.
    \329\ See FINRA April 2023 Letter at 8, n.23. The commenter also 
stated that ``TRF volume contributes to only a very small percentage 
of annual CAT compute and storage costs.'' FINRA May 2023 Letter at 
2.
    \330\ See FINRA April 2023 Letter at 8, n.23; FINRA May 2023 
Letter at 2.
    \331\ FINRA May 2023 Letter at 2.
---------------------------------------------------------------------------

    FINRA stated that, unlike the exchange Participants, transactions 
are not executed on a FINRA marketplace and FINRA does not receive 
commercial revenue for those transactions.\332\ FINRA explained that 
``while the NMS stock allocation to FINRA under the Funding Model is 
based on transactions that are reported to FINRA [TRFs], these 
transactions are not executed on a FINRA marketplace and FINRA does not 
retain commercial revenues from those transactions'' \333\ unlike the 
exchanges that operate each FINRA TRF, which retain the market data and 
trade reporting revenue of the TRF.\334\ FINRA stated that, unlike 
itself, these exchanges would thus have a revenue stream related to the 
transactions that would be assessed a CAT fee, and that also, unlike 
FINRA, exchanges generate revenue from listings and proprietary data 
feeds in NMS securities.\335\ FINRA also stated that FINRA members can 
report over-the-counter transactions in listed stocks to the FINRA 
Alternative Display Facility, although most transactions are reported 
to a TRF.\336\
---------------------------------------------------------------------------

    \332\ See FINRA April 2023 Letter at 3.
    \333\ Id.
    \334\ Id.
    \335\ Id. at 4.
    \336\ Id. at 3, n.8.
---------------------------------------------------------------------------

    FINRA further stated that it cannot necessarily recoup its costs 
through RSAs that it has entered into with

[[Page 62644]]

certain exchanges \337\ because the exchanges must first agree to be 
charged CAT costs under the RSAs; therefore, RSAs would not be a 
reliable source of CAT funding for FINRA.\338\ Additionally, FINRA 
questioned CAT LLC's statement that the Proposed Amendment ``reflects a 
reasonable effort to allocate costs based on the extent to which 
different CAT Reporters participate in and benefit from the equities 
and options markets.'' \339\ Specifically, FINRA asked how this 
explains the size of its allocation \340\ and noted that this statement 
``conflates the costs to create and operate the CAT with the usage of 
CAT data.'' \341\
---------------------------------------------------------------------------

    \337\ This statement was made in response to a statement in the 
Proposed Amendment that FINRA, like the exchange Participants, has 
revenue sources other than membership fees, giving as an example the 
RSAs. See Notice, supra note 7, 88 FR at 17107.
    \338\ See FINRA April 2023 Letter at 4.
    \339\ Id. at 7.
    \340\ Id.
    \341\ Id.; see also FINRA June 2022 Letter at 6.
---------------------------------------------------------------------------

    In the Proposed Amendment, CAT LLC contested the view that FINRA 
should not be treated as a market center for CAT funding purposes 
merely because FINRA is not treated as a market center for governance 
purposes under the National Market System Plan Regarding Consolidated 
Equity Market Data (``CT Plan'').\342\ CAT LLC explained that the 
purpose and implementation of the CT Plan and the CAT NMS Plan are 
different.\343\ CAT LLC stated that while the CAT NMS Plan explicitly 
contemplates charging fees to all Participants, including FINRA,\344\ 
and that the CAT is solely for regulatory purposes, providing a 
regulatory system to facilitate the performance of the self-regulatory 
obligations of all of the Participants, including the exchanges and 
FINRA,\345\ ``[i]n contrast, the CT Plan governs the public 
dissemination of real-time consolidated equity market data for NMS 
stocks.'' \346\
---------------------------------------------------------------------------

    \342\ See Notice, supra note 7, 88 FR at 17108. See also Joint 
Industry Plan; Order Approving, as Modified, a National Market 
System Plan Regarding Consolidated Equity Market Data; Securities 
Exchange Act Release No. 92586 (Aug. 6, 2021), 86 FR 44142 (Aug. 11, 
2021) (File No. 4-757) (``Order Approving the CT Plan''). The Order 
Approving the CT Plan was vacated by the D.C. Circuit on July 5, 
2022. See The NASDAQ Stock Market LLC et al. v. SEC, Case No. 21-
1167, D.C. Cir. (July 5, 2022). See also Securities Exchange Act 
Release No. 88827; File No. 4-757 (May 6, 2020), 85 FR 28702 (May 
13, 2020) (Order Directing the Exchanges and the Financial Industry 
Regulatory Authority to Submit a New National Market System Plan 
Regarding Consolidated Equity Market Data).
    \343\ See Notice, supra note 7, 88 FR at 17108.
    \344\ See CAT NMS Plan, supra note 2, at Sections 11.2 and 11.3.
    \345\ See Notice, supra note 7, 88 FR at 17108.
    \346\ Id.
---------------------------------------------------------------------------

    Certain commenters expressed concern about alleged arbitrary 
treatment of FINRA by the other Participants of the CAT NMS Plan.\347\ 
FINRA believes that its ``outsized allocation'' \348\ was because of 
its limited voting power, only having one out of 25 votes on the 
Operating Committee as it does not control, nor is under common control 
with, any other Participant.\349\ Another commenter stated that the 
current CAT NMS Plan voting structure results in the unfair and 
inequitable treatment of FINRA.\350\ Both commenters believe that the 
exchange Participants treat FINRA arbitrarily to benefit themselves, 
treating FINRA as a market center in the CAT NMS Plan while not as a 
market center under the CT Plan, which governs the public dissemination 
of real-time consolidated market data for national market system 
stocks.\351\ One commenter stated that the Participants do not treat 
FINRA as a market center under the CT Plan in order to limit FINRA's 
voting power and therefore its ability to decide how to allocate market 
data revenue.\352\ The commenter stated that this example demonstrates 
the ``. . . inherent conflicts of interest that for-profit exchanges 
have in operating as SROs. . .'' \353\
---------------------------------------------------------------------------

    \347\ See FINRA April 2023 Letter at 6; SIFMA October 2022 
Letter at 3. See also SIFMA May 2023 Letter at 6, n.11.
    \348\ FINRA April 2023 Letter at 7; FINRA June 2022 Letter at 6.
    \349\ FINRA April 2023 Letter at 4, 8. See also FINRA June 2022 
Letter at 8.
    \350\ See SIFMA January 2023 Letter at 3, n.7.
    \351\ See FINRA April 2023 Letter at 6, n.16; SIFMA October 2022 
Letter at 3. See also SIFMA May 2023 Letter at 6, n.11. One 
commenter stated that the Participants treat FINRA in ways that are 
financially beneficial to them without considering FINRA's role in 
the marketplace ``. . . as the not-for-profit self-regulator for the 
entire brokerage industry. . .'' SIFMA October 2022 Letter at 3. See 
also SIFMA January 2023 Letter at 4; SIFMA October 2022 Letter at 4; 
SIFMA May 2023 Letter at 8 (recommending that FINRA be treated 
differently from the Participant exchanges due to its unique role).
    \352\ See SIFMA October 2022 Letter at 3-4. See also SIFMA May 
2023 Letter at 6, n.11.
    \353\ SIFMA October 2022 Letter at 3. See also SIFMA June 2023 
Letter at 4 (quoting a Commission release stating that the 
Participants are potentially conflicted in allocating CAT fees to 
themselves and the Industry Members); supra note 64.
---------------------------------------------------------------------------

    Certain commenters suggested that the Commission issue an order 
soliciting comment on whether the Operating Committee should be 
reorganized consistent with the CT Plan.\354\ One commenter stated, 
``[w]e believe such a governance structure for the CAT would help 
facilitate a fairer structure for the views of the SROs and industry to 
be heard and incorporated into any further CAT funding proposal by 
reducing the ability of the largest exchange groups to dictate the 
terms of any CAT funding proposal over the objections of other SRO 
Participants and the industry.'' \355\
---------------------------------------------------------------------------

    \354\ SIFMA October 2022 Letter at 2. See also infra Section 
III.A.9.f. (suggesting changes to the governance structure of the 
CAT NMS Plan); see also MMI July Letter at 1-3. The latter commenter 
also felt that there should be a disclosure of the conflicts of 
interest the commenter believes are inherent in having the funding 
model determined by the Participants.).
    \355\ SIFMA October 2022 Letter at 2. The commenter also stated 
that the Industry Members are not voting members of the Operating 
Committee and have no way to direct the cost control efforts of the 
Participants or change their course if the cost control efforts 
prove to be unsuccessful. See SIFMA June 2022 Letter at 8.
---------------------------------------------------------------------------

    Commenters also believe the allocation to FINRA would increase the 
allocation to Industry Members.\356\ FINRA stated that because it 
relies on regulatory fees from its members for funding, it must 
increase its member fees in order to fund CAT costs that it cannot 
recover from contractual arrangements with TRF business members.\357\ 
FINRA stated that the Proposed Amendment does not adequately analyze 
the allocation's impact, including whether the allocation would 
increase Industry Members' allocation of total costs beyond two-
thirds.\358\ FINRA dismissed as inadequate the Participants' argument 
that Industry Members can pass through their costs, stating that the 
Proposed Amendment lacks a detailed description of and transparency 
into how the fees may be passed on to customers.\359\ Another commenter 
stated that the Participants ``do not address the fact that the 
Executed Share Model for Prospective CAT Costs allocates two-thirds of 
CAT costs to Industry Members for exchange transactions and more for 
off-exchange transactions'' \360\ because they cannot demonstrate that 
the proposed allocation results in an equitable allocation of 
reasonable fees.\361\ The commenter stated that Industry Members, who 
would be subject to two-thirds of Prospective CAT Costs under the 
Executed Share Model, already pay FINRA's operating costs through 
regulatory fines and fees;

[[Page 62645]]

therefore, Industry Members would additionally be indirectly assessed 
FINRA's one-third CAT fee for off-exchange transactions.\362\ The 
commenter suggested an alternative allocation \363\ that would subject 
FINRA only to a nominal regulatory user fee to access CAT Data.\364\
---------------------------------------------------------------------------

    \356\ See FINRA April 2023 Letter at 5-7; SIFMA June 2022 Letter 
at 4; Citadel July Letter at 2, 16, 21, supra notes 73-74 and 
accompanying text. See also SIFMA October 2022 Letter at 2, 3.
    \357\ See FINRA April 2023 Letter at 5-6. See also FINRA June 
2022 Letter at 7.
    \358\ See FINRA April 2023 Letter at 6.
    \359\ Id. at 6-7.
    \360\ SIFMA June 2022 Letter at 4. See also SIFMA October 2022 
Letter at 3 (``. . . we believe the proposal is flawed because it 
fails to appropriately consider that Industry Members pay the full 
costs of operating FINRA.'').
    \361\ See SIFMA June 2022 Letter at 4.
    \362\ Id. The commenter also stated that the proposed allocation 
would result in two-thirds of CAT costs for exchange transactions 
being imposed on Industry Members, and that this amount would be 
higher for off-exchange transactions as FINRA would be assessed one-
third as the venue fee and Industry Members would be indirectly 
assessed FINRA's portion of CAT costs as they pay the entire costs 
of operating FINRA. Id. See also SIFMA October 2022 Letter at 2.
    \363\ See supra notes 100-101 and accompanying text.
    \364\ See SIFMA January 2023 Letter at 4. See also SIFMA May 
2023 Letter at 8; SIFMA June 2022 Letter at 5; SIFMA October 2022 
Letter at 4; supra notes 100-101 and accompanying text.
---------------------------------------------------------------------------

    CAT LLC disagreed with the commenter's proposal to charge FINRA 
only a nominal regulatory fee.\365\ CAT LLC stated that the proposed 
transaction-based CAT fee is purposely agnostic as to the location of 
where a trade occurs, and an intent of this design is to avoid 
influencing whether or where any trading activity would take place. 
Moreover, CAT LLC stated that FINRA is no different from the exchanges 
in terms of its regulatory obligations regarding the CAT.\366\ CAT LLC 
also stated that FINRA's allocation is ``fair and reasonable as FINRA 
is currently, and is expected to continue to be, one of the largest 
regulatory users of the CAT, and it is responsible for the oversight of 
the very large over-the-counter securities market.'' \367\
---------------------------------------------------------------------------

    \365\ See CAT LLC May 2023 Response Letter at 8.
    \366\ Id.
    \367\ See CAT LLC July 2023 Response Letter at 35.
---------------------------------------------------------------------------

    FINRA requested that if the Commission were to approve the Proposed 
Amendment, that it acknowledge ``FINRA's need and ability to cover CAT 
costs that are not recovered through contractual arrangements through 
member fee increases, so as not to jeopardize FINRA's ability to carry 
out its critical regulatory mission.'' \368\ FINRA also stated that it 
would file a rule change to increase its member fees with the filing of 
any proposed rule change to effectuate the Funding Model.\369\
---------------------------------------------------------------------------

    \368\ FINRA April 2023 Letter at 7.
    \369\ Id.
---------------------------------------------------------------------------

    The Commission acknowledges the comments objecting to the 
allocation to FINRA of 34% of the total CAT costs to be borne by 
Participants,\370\ but believes that it is reasonable for the Proposed 
Amendment to assess fees to FINRA based on executed equivalent share 
volume like the other Participants for purposes of CAT funding. FINRA 
is a Participant of the CAT NMS Plan. All Participants are mandated 
under the CAT NMS Plan to fund the CAT.\371\ The Executed Share Model 
would assess CAT fees based on executed equivalent share volume. Under 
the Executed Share Model, CAT fees would be allocated among the buyer, 
seller, and the market regulator in each transaction. FINRA would pay 
the Participant CAT fee based on off-exchange trades reported by its 
members to its trade reporting facilities because FINRA is the market 
regulator responsible for the market in which the TRF transactions 
occur. The Executed Share Model, like the current funding model, is 
designed to allocate CAT fees among the Participants based on market 
share. Since FINRA is generally the market regulator for the over-the-
counter markets, its CAT fees, and thus market share, will be based on 
the trading activity in the over-the-counter markets reported to it by 
its members. The trading volume of the over-the-counter markets is 
greater than that on the exchanges; consequently, FINRA will likely be 
allocated a greater executed equivalent share volume than the other 
Participants. However, trading volume generates costs for CAT, 
therefore, given its role overseeing the over-the-counter market, it is 
reasonable for FINRA to incur a greater share of CAT fees based on the 
over-the-counter market's trading volume. As discussed above, it is 
difficult to calculate each CAT Reporter's individual cost burden on 
the CAT, and a reasonable proxy for CAT cost burden must be used. The 
proposed use of executed equivalent share volume is a reasonable method 
of allocating costs because it is readily determinable and equitable 
since executed share volume is based on trading activity, which impacts 
CAT costs. In practice, CAT Reporters will be assessed fees 
corresponding to the cost burden they impose on the CAT through their 
trading activity, or in FINRA's case, trading activity in the over-the-
counter markets reported to it by its members.
---------------------------------------------------------------------------

    \370\ Id. at 3; SIFMA May 2023 Letter at 2.
    \371\ See CAT NMS Plan, supra note 2, at Section 11.1(b); 
Section 11.3(a).
---------------------------------------------------------------------------

    The Commission recognizes that there could be other methodologies 
for allocating costs among CAT Reporters, such as allocations that take 
into account the manner in which each Participant earns revenue, but 
these other methodologies may be significantly more complex and would 
not necessarily more accurately reflect the cost burden of each CAT 
Reporter. CAT LLC chose to propose the use of executed equivalent share 
volume, explaining why trading activity is a reasonable proxy for cost 
burden and an appropriate metric for allocating CAT costs.\372\ 
Although there may be multiple permissible approaches to cost 
allocation, the proposed allocation of Participant CAT fees based on 
executed equivalent share volume is reasonable and meets the Rule 608 
approval standard.\373\
---------------------------------------------------------------------------

    \372\ See Notice, supra note 7, 88 FR at 17103.
    \373\ See 17 CFR 242.608(b)(2).
---------------------------------------------------------------------------

    The Commission agrees with CAT LLC that the Executed Share Model 
reasonably assesses fees to FINRA in the same manner based on 
transaction volume as other Participants. The Executed Share Model is 
reasonably designed to be neutral as to the manner of execution and 
place of execution.\374\ All Participants are self-regulatory 
organizations that have the same regulatory obligations under the 
Exchange Act, regardless of whether they operate as a for-profit or 
not-for-profit entity. Their regulatory responsibilities for the 
operations of CAT are the same.\375\
---------------------------------------------------------------------------

    \374\ See Notice, supra note 7, 88 FR at 17107.
    \375\ Id.
---------------------------------------------------------------------------

    The Commission acknowledges the concerns expressed by commenters 
that FINRA's allocation could indirectly increase the allocation of CAT 
fees to Industry Members since Industry Members contribute to FINRA's 
funding.\376\ As discussed above, however, the costs of CAT must be 
allocated between the Participants and Industry Members according to 
some formula. Although the Participants and Industry Members have 
different means of potentially recovering from others some of the costs 
allocated to them (e.g., the Participants from Industry Members and 
Industry Members from customers), it is reasonable to allocate costs 
evenly among the three parties who have primary roles related to the 
transaction. The Commission agrees with CAT LLC that Industry Members 
may be able to offset any fees that FINRA assesses them by passing 
their CAT fees through to their customers, just as they may do with 
Section 31-related fees and other fees. The Commission recognizes, 
however, that not all Industry Members currently pass through fees or 
would determine to do so in the future.
---------------------------------------------------------------------------

    \376\ See FINRA April 2023 Letter at 5-7; SIFMA June 2022 Letter 
at 4; Citadel July Letter at 2, 16, 21, supra notes 73-74 and 
accompanying text. See also SIFMA October 2022 Letter at 2, 3; FINRA 
June 2022 Letter at 4.
---------------------------------------------------------------------------

    Finally, the Commission does not agree that the Participants' 
treatment of FINRA is arbitrary because FINRA is treated as a market 
center for purposes

[[Page 62646]]

of determining its CAT funding obligations while the CT Plan, which 
governs the public dissemination of consolidated market data, would not 
have counted FINRA's market activity for purposes of determining the 
allocation of votes on the Operating Committee.\377\ The different 
treatment of FINRA in these NMS plans reasonably reflects the very 
different roles that a market center is used for in these contexts. The 
CT Plan provisions discussed by the commenters involve the 
determination of which Participant(s) could be eligible for a second 
vote on the Operating Committee,\378\ while the Executed Share Model 
proposes to assess FINRA a Participant CAT Fee based on its role as the 
regulator for the over-the-counter market in which such trades 
occur.\379\ The commenter's request that the Commission issue an order 
soliciting comment on whether the Operating Committee should be 
reorganized consistent with the CT Plan \380\ would be better addressed 
in the context of a separate plan amendment.
---------------------------------------------------------------------------

    \377\ The CT Plan provided that an exchange group or independent 
exchange that has more than 15 percent of consolidated equity market 
share during four of the six calendar months preceding a vote of the 
operating committee would be authorized to cast two votes. The CT 
Plan stated that FINRA is not considered a market center for 
purposes of determining consolidated equity market share solely by 
virtue of facilitating trades through any TRF that FINRA operates in 
affiliation with a national securities exchange designed to report 
transactions otherwise than on an exchange. See supra note 342.
    \378\ See FINRA April 2023 Letter at 6; SIFMA October 2022 
Letter at 3. See also SIFMA January 2023 Letter at 4; SIFMA October 
2022 Letter at 4; SIFMA May 2023 Letter at 8.
    \379\ See supra notes 371-372 and accompanying text.
    \380\ See SIFMA October 2022 Letter at 2.
---------------------------------------------------------------------------

4. CAT Executing Broker
    As noted above, CAT Executing Brokers will be charged CAT 
fees.\381\ CAT LLC proposed to add a definition of ``CAT Executing 
Broker'' to Section 1.1 of the CAT NMS Plan. The definition would 
explain which party would be identified as a CAT Executing Broker in a 
transaction.
---------------------------------------------------------------------------

    \381\ See Notice, supra note 7, 88 FR at 17087.
---------------------------------------------------------------------------

    With respect to transactions on an exchange and over-the-counter 
transactions, CAT LLC would use transaction reports reported to the CAT 
by FINRA or the exchanges to identify the transaction, as well as the 
CAT Executing Broker for each transaction, for purposes of calculating 
the CAT fees.\382\ Under the Participant Technical Specifications, for 
transactions occurring on a Participant exchange, there is a field for 
the exchange to report the market participant identifier (``MPID'') of 
``the member firm that is responsible for the order on this side of the 
trade.'' \383\ The Industry Members identified in these fields for the 
transaction reports would be the CAT Executing Brokers for transactions 
executed on an exchange.\384\ FINRA is required to report to the CAT 
transactions in Eligible Securities reported to a FINRA trade reporting 
facility (i.e., the TRF, Over-the Counter Reporting Facility (``ORF'') 
and Alternative Display Facility (``ADF'')).\385\ Under the Participant 
Technical Specifications, for such transactions reported to a FINRA 
trade reporting facility, FINRA is required to report the MPID of the 
executing party as well as the MPID of the contra-side executing 
party.\386\ The Industry Members identified in these two fields for the 
transaction reports would be the CAT Executing Brokers for over-the-
counter transactions.\387\
---------------------------------------------------------------------------

    \382\ Id. at 17088. The transaction reports used to identify 
transactions and CAT Executing Brokers do not provide for fractional 
quantities; therefore, CAT fees would not be calculated using 
fractional shares or fractional share components of executed orders. 
Id. at 17089. See supra notes 280-266 and accompanying text.
    \383\ Section 4.7 (Order Trade Event) and Section 5.2.5.1 
(Simple Option Trade Event: Side Details) of the CAT Reporting 
Technical Specifications for Plan Participants, Version 4.1.0-r17 
(Feb. 21, 2023), <a href="https://www.catnmsplan.com/sites/default/files/2023-02/02.21.2023-CAT-Reporting-Technical-Specifications-for-Participants-4.1.0-r17.pdf">https://www.catnmsplan.com/sites/default/files/2023-02/02.21.2023-CAT-Reporting-Technical-Specifications-for-Participants-4.1.0-r17.pdf</a>.
    \384\ See Notice, supra note 7, 88 FR at 17087-88.
    \385\ See Section 6.1 of the CAT Reporting Technical 
Specifications for Plan Participants (Feb. 21, 2023). A CAT 
Executing Broker in over-the-counter transactions identified on the 
TRF/ORF/ADF Transaction Data Event is determined based on the tape 
or media report, that is, a trade report that is submitted to a 
FINRA trade reporting facility and reported to and publicly 
disseminated by the appropriate exclusive Securities Information 
Processor. A CAT Executing Broker for over-the-counter transactions 
is not determined based on a non-tape report (e.g., a regulatory 
report or a clearing report), which is not publicly disseminated. 
There is an exception to this statement for away-from-market trades. 
These are non-media trades reported to the TRF with an ``SRO 
Required Modifier Code'' of ``R''.
    \386\ See Notice, supra note 7, 88 FR at 17087-88.
    \387\ Id. at 17088.
---------------------------------------------------------------------------

    For transactions on ATSs, if an ATS is identified as the executing 
party and/or the contra-side executing party in the TRF/ORF/ADF 
Transaction Data Event, then the ATS would be a CAT Executing Broker 
for purposes of the Executed Share Model.\388\ If the ATS is identified 
as the executing party for the buyer in such transaction reports, then 
the ATS would be the CEBB.\389\ If the ATS is identified as the 
executing party for the seller in such transaction reports, then the 
ATS would be the CEBS.\390\ If the ATS is identified as both the 
executing party and contra-side executing party, the ATS would be both 
the CEBB and the CEBS.\391\ ATSs would determine the executing party 
and the contra-side executing party reported to FINRA's equity trading 
facilities in accordance with the transaction reporting requirements 
for FINRA's equity trading facilities.\392\
---------------------------------------------------------------------------

    \388\ Id. at 17088-89.
    \389\ Id. at 17089.
    \390\ Id.
    \391\ Id. See also FINRA, Trade Reporting Frequently Asked 
Questions at Section 203, available at <a href="https://www.finra.org/filing-reporting/market-transparency-reporting/trade-reporting-faq#203">https://www.finra.org/filing-reporting/market-transparency-reporting/trade-reporting-faq#203</a>; 
FINRA Regulatory Notice 09-08, available at <a href="https://www.finra.org/rules-guidance/notices/09-08">https://www.finra.org/rules-guidance/notices/09-08</a>.
    \392\ See Notice, supra note 7, 88 FR at 17089.
---------------------------------------------------------------------------

    For transactions that do not occur on an exchange and there is only 
a FINRA member identified for one side of the trade, that FINRA member 
would be treated as the CAT Executing Broker for both the buy-side and 
the sell-side of the transaction, that is, as the CEBS and CEBB.\393\ 
Additionally, ``[f]or any trade report on which a Canadian non-member 
appears as a party to the trade, the FINRA member must appear as the 
reporting party.'' \394\ In this situation, the executing broker 
identified in the ``reportingExecutingMpid'' field would be billed for 
both sides of the transaction.\395\
---------------------------------------------------------------------------

    \393\ See proposed Section 1.1. (definition of ``CAT Executing 
Broker'').
    \394\ Notice, supra note 7, 88 FR at 17089.
    \395\ Id.
---------------------------------------------------------------------------

    The Executed Share Model also provides for cancellations and 
corrections.\396\ CAT LLC stated that it expects to determine CAT fees 
based on the transaction reports for a month as of a particular 
day.\397\ To the extent that changes are made to the transaction 
reports on or before the day the CAT fees are determined for the given 
month, the changes will be reflected in the monthly bill.\398\ To the 
extent that changes are made to the transaction reports after the day 
the CAT fees are determined for that month, subsequent bills will 
reflect any changes via debits or credits, as applicable.\399\ CAT LLC 
represented that it will establish specific policies and procedures 
regarding the treatment of such adjustments as those related to 
cancellations and corrections, as is required under the CAT NMS Plan to 
adopt policies, procedures, and practices regarding the billing and 
collection of fees.\400\ Furthermore, CAT LLC stated that it will 
inform Industry Members and other market participants

[[Page 62647]]

of these policies and procedures via FAQs, CAT Alerts and/or other 
appropriate methods.\401\
---------------------------------------------------------------------------

    \396\ Id.
    \397\ Id.
    \398\ Id.
    \399\ Id.
    \400\ See CAT NMS Plan, supra note 2, at Section 11.1(d).
    \401\ See Notice, supra note 7, 88 FR at 17089.
---------------------------------------------------------------------------

    Certain commenters objected to the proposed definition of ``CAT 
Executing Broker.'' \402\ One commenter stated that the term ``CAT 
Executing Broker'' ``does not appear to be universally defined or 
accepted by Option Industry Members or Participants'' and that such 
lack of acceptance ``present[s] a challenge when firms try to assess 
the impact the `Funding Proposal' will have on their respective 
businesses.'' \403\ Accordingly, the commenter advocated that the 
Executed Share Model follow the ``structure already in place for 
[collecting] Regulatory Fees,'' such as charging Clearing Brokers.\404\
---------------------------------------------------------------------------

    \402\ See SIFMA May 2023 Letter; Letter from Timothy Miller, 
Chief Operating Officer, DASH Financial Technologies, LLC to Vanessa 
Countryman, Secretary, Commission (July 13, 2023) (``DASH July 2023 
Letter''), at 1-2; Letter from Timothy Miller, Chief Operating 
Officer, DASH Financial Technologies, LLC to Vanessa Countryman, 
Secretary, Commission (April 11, 2023) (``DASH April 2023 Letter''), 
at 1-2. Both the DASH July 2023 Letter and the DASH April 2023 
Letter incorporated by reference a separate letter submitted by the 
commenter on the prior funding proposal (stating that the concerns 
expressed in the prior letter concerning the operating and 
competitive burdens of the proposed funding model are unchanged). 
See Letter from Timothy Miller, Chief Operating Officer, DASH 
Financial Technologies LLC, to Vanessa Countryman, Secretary, 
Commission (Jan. 3, 2023) (``DASH January 2023 Letter'').
    \403\ DASH April 2023 Letter at 1. See also DASH July 2023 
Letter at 1-2.
    \404\ DASH April 2023 Letter at 2. See also DASH July 2023 
Letter at 1-2. The commenter reiterated that it believes clearing 
firms are still best suited to process the collection of fees, as 
this can occur at trade settlement and the cost is ultimately borne 
by the end beneficiary of each transaction. The commenter further 
stated that ``there is precedent to follow with other Regulatory 
Fees, such as ORF and OCC, to streamline the workflow and reduce the 
number of counterparties involved in the payment/collection 
process,'' and ``that in the options industry, ORF and Section 31 
fees are not consistently billed to the exchange facing member; but, 
most of the time, these fees follow the clearing firm associated 
with the order.''
---------------------------------------------------------------------------

    Another commenter stated that the proposed definition of executing 
broker would result in the inequitable allocation of fees.\405\ While 
the commenter supported the change from having clearing firms be 
assessed Industry Member CAT fees to executing brokers having this 
obligation,\406\ because clearing firms would have been unfairly 
burdened with CAT costs and could have been placed in situations in 
which they would have been unable to identify the client responsible 
for the costs,\407\ the commenter expressed concerns with how the 
Participants determined which entities would be considered executing 
brokers.\408\ In comment letters on the prior funding model 
proposal,\409\ which was amended to require executing brokers instead 
of clearing firms to be assessed CAT fees,\410\ the commenter requested 
additional detail on how an executing broker would be defined.\411\ The 
commenter subsequently stated that the definition in the current 
Proposed Amendment suffers from the same problems as the prior proposal 
in which CAT fees were allocated to clearing firms and would result in 
the inequitable allocation of CAT fees among Industry Members.\412\
---------------------------------------------------------------------------

    \405\ See SIFMA May 2023 Letter at 3.
    \406\ Id. See also SIFMA January 2023 Letter at 7-8.
    \407\ See SIFMA May 2023 Letter at 3-4. See also SIFMA October 
2022 Letter at 5. The commenter also expressed concerns about the 
assessment of CAT fees on clearing firms because clearing firms 
would be required to collect fees and thus would have to develop new 
systems and processes under the Executed Share Model, and because a 
clearing firm for a buyer or seller would not always be a party to a 
trade as it could be the clearer of a trade on behalf of an 
executing broker. See SIFMA June 2022 Letter at 9; SIFMA October 
2022 Letter at 7.
    \408\ See SIFMA May 2023 Letter at 4.
    \409\ See Securities Exchange Act Release No. 94984 (May 25, 
2022), 87 FR 33226 (June 1, 2022) (``Prior Funding Model 
Proposal'').
    \410\ Two partial amendments were submitted on the Prior Funding 
Model Proposal. The first partial amendment initially proposed the 
use of executing brokers. See Securities Exchange Act Release No. 
96394 (Nov. 28, 2022), 87 FR 74183 (Dec. 3, 2022). The Prior Funding 
Model Proposal, as modified by the two partial amendments, was 
withdrawn by the Participants on March 1, 2023. See Securities 
Exchange Act Release No. 97212 (Mar. 28, 2023), 88 FR 19693 (Apr. 3, 
2023).
    \411\ See SIFMA January 2023 Letter at 2, 8; SIFMA December 2022 
Letter at 3. See also SIFMA May 2023 Letter at 4.
    \412\ See SIFMA May 2023 Letter at 4. See also SIFMA June 2022 
Letter at 9-10; SIFMA October 2022 Letter at 5.
---------------------------------------------------------------------------

    The commenter explained that CAT operates on a cost-recovery basis, 
with costs resulting from the number of messages that Participants and 
Industry Members report to the CAT, the processing and linking of such 
messages, and the costs of providing tools to regulators to analyze CAT 
data.\413\ The commenter stated that the use of message traffic as the 
basis of fees, in the Original Funding Model, would have ensured that 
all CAT Reporters would contribute to CAT's funding.\414\ However, the 
commenter stated that, since the Proposed Amendment would not impose 
fees on all CAT Reporters, instead imposing fees on executing brokers, 
it would result in an inequitable allocation of fees as the executing 
brokers would be the last broker among many other brokers handling an 
order.\415\ The commenter stated that any analysis of such a funding 
model must evaluate whether (i) the executing brokers would pass-
through or absorb the CAT fees and any negative impacts on competition, 
noting that the Proposed Amendment would require executing brokers to 
incur expenses that other Industry Members would not incur since they 
would be required to collect the Industry Member portion of CAT fees on 
behalf of the Participants,\416\ and (ii) Industry Members that 
executed trades for introducing brokers and acted as order 
consolidators and ATSs would be responsible for CAT fees for 
transactions they did not originate and would have to either pay the 
fee for their clients or develop software and processes to collect the 
fees from their clients as they often are not capable of passing 
through fees to the clients that sent them the orders.\417\ The 
commenter stated that the Proposed Amendment would subject executing 
brokers to unfair burdens and require them to ``shoulder CAT costs in 
scenarios in which they could not determine which client firm was 
responsible for creating the CAT costs by initiating the transaction.'' 
\418\
---------------------------------------------------------------------------

    \413\ See SIFMA May 2023 Letter at 4.
    \414\ Id.
    \415\ Id. at 4-5.
    \416\ Id. at 5. See also Virtu Letter at 5 (stating that it is 
``highly likely'' that executing brokers would end up absorbing the 
fees themselves, as they would not have the systems in place to 
trace to whom the fees were properly allocable).
    \417\ See SIFMA May 2023 Letter at 5.
    \418\ Id. Another commenter similarly objected to the imposition 
of CAT fees on Executing Brokers. This commenter, a major wholesaler 
who also serves as the Executing Broker on many transactions, stated 
it was unjust to disproportionately burden Executing Brokers in this 
manner, and noted that the cost of designing processes and systems 
to route the fees to the appropriate parties could be prohibitive to 
smaller brokers. See Virtu Letter at 4-5.
---------------------------------------------------------------------------

    The commenter suggested instead an allocation in which the Industry 
Member that originated an order would be treated as an ``executing 
broker'' and therefore be responsible for Industry Member CAT 
fees.\419\ Under this alternative, ``the Industry Member who originates 
a new principal order or the Industry Member who initially receives and 
routes a customer order for execution on an agency basis would be 
directly assessed CAT Fees.'' \420\ The commenter stated that this 
would be the most reasonable way to allocate CAT costs among Industry 
Members \421\ and that it would be ``relatively easy to accommodate 
this approach.'' \422\ One other commenter also suggested allocating 
costs to the party originating an order, stating that this would

[[Page 62648]]

``streamline the process and more accurately allocate costs . . .'' 
\423\
---------------------------------------------------------------------------

    \419\ See SIFMA May 2023 Letter at 5.
    \420\ Id. at 6.
    \421\ Id. at 5.
    \422\ Id. at 6.
    \423\ See Citadel July Letter at 20. See also id. at 3, 30, 31.
---------------------------------------------------------------------------

    One commenter expressed concerns about the imposition of CAT fees 
on CAT Executing Brokers.\424\ The commenter stated that charging CAT 
Executing Brokers ``inordinately burdens Broker Dealers, especially 
small to medium-sized firms.'' \425\ This commenter recommended using 
instead the existing structure for regulatory fees, including ``the 
efficiencies afforded by the current structure, and the resulting 
alleviation of risk.'' \426\ In this regard, the commenter stated that 
``Clearing Firms are best suited to process the collection of fees as 
it can occur at trade settlement and the cost is ultimately borne by 
the end beneficiary of each transaction.'' \427\ The commenter also 
stated that small and medium-sized executing brokers could expect a 
significant negative impact on their net capital as a result of the 
proposal, stating, ``. . . the firms will be forced to recoup these 
costs by passing them on to their clients, either in the form of higher 
commission rates or as a separate transactional fee. Using [Clearing 
Member Trade Agreement] commission invoicing and/or SEC 31(b) fees in a 
broker-to-broker relationship as a proxy, these invoices are generally 
paid well after the 60-day milestone to qualify the receivable as `good 
capital.' '' \428\
---------------------------------------------------------------------------

    \424\ See DASH April 2023 Letter. See also DASH July 2023 Letter 
at 1-2.
    \425\ See DASH April 2023 Letter at 1. See also DASH January 
2023 Letter at 1; DASH July 2023 Letter at 1.
    \426\ DASH January 2023 Letter at 3. See also DASH April 2023 
Letter at 1-2; DASH July 2023 Letter at 1-2.
    \427\ DASH April 2023 Letter at 1. See also DASH January 2023 
Letter at 1; DASH July 2023 Letter at 1.
    \428\ DASH January 2023 Letter at 2; DASH July 2023 Letter at 1-
2.
---------------------------------------------------------------------------

    In response to the comment about the definition of CAT Executing 
Broker and the billing and collection process being better suited for 
clearing firms, CAT LLC stated that the proposed assessment of CAT fees 
on CAT Executing Brokers only addresses the party obligated to pay the 
CAT fee.\429\ CAT LLC stated that a CAT Executing Broker would not be 
required to follow a particular process for paying CAT fees, as it 
could pay the fees itself, or require a clearing firm or other third 
party to pay CAT fees on its behalf.\430\ For example, CAT LLC stated 
that a CAT Executing Broker can decide to enter into an arrangement 
with its clearing broker for the clearing broker to collect and pass-
through the CAT fees like it does in other contexts.\431\
---------------------------------------------------------------------------

    \429\ See CAT LLC May 2023 Response Letter at 12; CAT LLC July 
2023 Response Letter at 3.
    \430\ See CAT LLC July 2023 Response Letter at 3.
    \431\ CAT LLC May 2023 Response Letter at 12.
---------------------------------------------------------------------------

    With respect to alternatives to the proposed definition of the CAT 
Executing Broker, CAT LLC stated that the ``originating broker'' 
suggestion was from a commenter who had previously recommended charging 
executing brokers in comment letters on the Prior Funding Model 
Proposal.\432\ CAT LLC stated that the commenter's objection to 
charging executing brokers in the Executed Share Model was an attempt 
to further delay the approval of a funding model and the resultant 
payment of CAT fees by its members, rather than expressing a concern 
about the merits of charging executing brokers.\433\
---------------------------------------------------------------------------

    \432\ Id. at 2. See also supra note 409.
    \433\ CAT LLC May 2023 Response Letter at 3.
---------------------------------------------------------------------------

    In response, the commenter stated that the Operating Committee 
mischaracterized the commenter's position on the assessment of CAT fees 
to executing brokers by stating in the CAT LLC Response Letter that the 
commenter changed its position on this proposed change to delay 
adoption of a CAT funding model.\434\ The commenter represented that it 
stated in comment letters it submitted on the Prior Funding Model 
Proposal \435\ that initially proposed the use of executing brokers 
\436\ that (1) the Participants did not define who would be an 
executing broker in a transaction, (2) a clear definition is necessary 
for Industry Members to understand when they would be assessed costs 
under the Executed Share Model, and (3) its understanding was that the 
concept of executing broker generally refers to the Industry Member 
that initiates an order.\437\ The commenter stated that the 
Participants only provided a definition of executing broker in the 
Proposed Amendment.\438\ The commenter stated that it provided concerns 
about the proposed definition in its May 2023 comment letter, which the 
commenter stated were mischaracterized by the Operating Committee in 
the CAT LLC Response Letter in an attempt to rush the Commission to a 
decision on the Proposed Amendment.\439\
---------------------------------------------------------------------------

    \434\ See SIFMA June 2023 Letter at 5.
    \435\ See supra note 409.
    \436\ See supra note 410.
    \437\ See SIFMA June 2023 Letter at 5.
    \438\ Id.
    \439\ Id. at 5-6.
---------------------------------------------------------------------------

    In response to the comment that imposing fees on executing brokers 
would result in an inequitable allocation of fees and the suggestion 
that the use of message traffic as the basis of fees would have ensured 
that all CAT Reporters would contribute to CAT's funding, CAT LLC 
disagreed and stated that because the message traffic is separate from 
whether or not a transaction occurs, fees based on message traffic may 
not correlate with common revenue or fee models.\440\ CAT LLC stated 
that, as a result, CAT fees based on message traffic could impose an 
outsized adverse financial impact on certain Industry Members, raising 
this same issue of an inequitable allocation of fees.\441\ Further, in 
response to the commenter's criticism that in charging executing 
brokers, the fee would be charged to a subset of Industry Members and, 
as a result, that subset of Industry Members would incur expenses that 
other Industry Members would not incur, CAT LLC stated that it 
continues to believe that charging CAT Executing Brokers would satisfy 
the requirements of the Exchange Act.\442\ CAT LLC stated that in the 
past, the Commission has approved fees that are charged to some, but 
not all, broker-dealers.\443\ CAT LLC noted that, for example, FINRA's 
TAF is assessed to a subset of FINRA members--that is, it is assessed 
on the sell side of member transactions.\444\ CAT LLC also stated that 
the options exchanges charge options regulatory fees per executed 
contract side, and, for both options and equities, Section 31-related 
fees are charged to the sell-side in a transaction.\445\ CAT LLC 
recognized that, under the proposal to charge CAT Executing Brokers, 
the CAT Executing Broker, but not other Industry Members involved in a 
given order lifecycle, would be required to pay the CAT fees, and that 
Industry Members that sought to recoup such fees would have to develop 
processes to collect such fees from their clients.\446\ CAT LLC stated 
that this regulatory requirement would have a similar effect as other 
types of regulatory fees, such as the FINRA TAF, the options regulatory 
fee and Section 31-related sales value pass-through fees because, 
``[i]n each such case, a subset of broker-dealers is required to pay a 
transaction-based regulatory fee, and those broker-dealers seeking to 
recover such fees from other broker-dealers or non-broker-dealers have 
established processes with regard to the pass-through of such fees.'' 
\447\
---------------------------------------------------------------------------

    \440\ See CAT LLC May 2023 Response Letter at 4.
    \441\ Id.
    \442\ Id. at 3.
    \443\ Id.
    \444\ Id.
    \445\ Id.
    \446\ See CAT LLC May 2023 Response Letter at 4.
    \447\ Id.
---------------------------------------------------------------------------

    CAT LLC further stated that it disagrees with charging an 
originating

[[Page 62649]]

broker instead of an executing broker because there are already several 
existing examples of transaction-based fees being assessed to executing 
brokers as opposed to the originating broker (e.g., TAF, Section 31 
fees, ORF fees), and it disagrees with the assertion that charging 
originating brokers would be easier.\448\ CAT LLC stated that charging 
the originating Industry Member would be difficult to implement and 
would increase the costs of implementing CAT fees, whereas charging CAT 
Executing Brokers is simple, straightforward and in line with existing 
fee and business models because for any given trade (buy or sell), 
there is only one CAT Executing Broker to which shares can be 
allocated.\449\ As such, CAT LLC stated that ``charging the CAT 
Executing Broker is simple and straightforward, and leverages a one-to-
one relationship between billable events (trades) and billable 
parties.'' \450\ CAT LLC stated that, for a single trade event, there 
may be many originating brokers, and each trade must be broken down on 
a pro-rata basis, ``to account[] for one or more layers of aggregation, 
disaggregation, and representation of the underlying orders.'' \451\ 
Therefore, CAT LLC stated that one commenter's \452\ ``suggestion of a 
model that begins the funding analysis with new order events (e.g., 
MENO or MONO events) and then looks for any execution or fulfillment 
that is directly associated with that event does not reduce or mitigate 
the complexity associated with aggregation.'' \453\ Further, CAT LLC 
stated that the commenter's recommendation would not work with the 
design of the CAT system, stating that ``[w]hile CAT is indeed designed 
to capture and unwind complex aggregation scenarios, the data and 
linkages are structured to facilitate regulatory use, and not a billing 
mechanism that assesses fees on a distinct set of executed trades; it 
is not simply a matter of using existing CAT linkages.'' \454\ CAT LLC 
also stated that charging originating brokers would implicate issues 
related to lifecycle linkage rates, and issues related to corrections, 
cancellations and allocations, but charging CAT Executing Brokers would 
avoid such complications.\455\ CAT LLC also stated that allocating to 
the originating broker would not include Industry Members that were 
only involved in routing and execution, which would include ``some of 
the largest Industry Members,'' \456\ and that these Industry Members 
``are not involved in the origination of orders or originate few orders 
in relation to their overall market activity.'' \457\ Furthermore, CAT 
LLC stated that originating brokers would also need to establish 
processes for paying CAT fees, just as CAT Executing Brokers 
would.\458\
---------------------------------------------------------------------------

    \448\ Id. at 5. See also CAT LLC July 2023 Response Letter at 3-
4, 4 (detailing challenges of allocating CAT costs to originating 
brokers).
    \449\ See CAT LLC May 2023 Response Letter at 5. See also CAT 
LLC July 2023 Response Letter at 3.
    \450\ CAT LLC May 2023 Response Letter at 5. See also CAT LLC 
July 2023 Response Letter at 4.
    \451\ CAT LLC May 2023 Response Letter at 5. See also CAT LLC 
July 2023 Response Letter at 3.
    \452\ See SIFMA May 2023 Letter at 5.
    \453\ See CAT LLC May 2023 Response Letter at 5.
    \454\ Id.
    \455\ Id.
    \456\ See CAT LLC July 2023 Response Letter at 3.
    \457\ Id.
    \458\ Id.
---------------------------------------------------------------------------

    One commenter expressed uncertainty about CAT LLC's response that 
some of the largest Industry Members are not involved in order 
origination or originate few orders relative to their market activity, 
stating that it is unclear to whom the statement is referring since the 
executing broker and the originating broker would be the same firm in 
the case of proprietary trading activity.\459\ Additionally, the 
commenter stated that the originating broker model should be pursued if 
it dramatically reduces market-wide implementation costs with a 
marginal increase in CAT costs, noting that Industry Members could bear 
most, if not all, CAT costs to implement the originating broker 
model.\460\ The commenter stated that, before proceeding, the CAT 
Operating Committee must publish an analysis of the costs and benefits 
of the executing broker and originating broker models including any 
differences in CAT implementation costs and Industry Member 
implementation costs.\461\
---------------------------------------------------------------------------

    \459\ See Citadel August Letter at 6.
    \460\ Id.
    \461\ Id.
---------------------------------------------------------------------------

    In response to a comment stating that executing brokers lacked 
systems and processes to recover costs from their clients and would 
either choose to absorb the CAT fees or exit the business because of 
the investments necessary for the cost-recovery process,\462\ CAT LLC 
stated that those Industry Members that pass-through CAT fees will 
accordingly need to develop processes to recover the fees from their 
clients, like they do for other regulatory-related fees, like the TAF, 
the options regulatory fee and Section 31-related fees.\463\ CAT LLC 
also stated that CAT Executing Brokers would ``have full discretion as 
to whether and the manner and extent to which they pass on their CAT 
fees, if at all,'' noting that ``a CAT Executing Broker could round up 
its fees to the nearest cent, or decide to charge for, or not charge 
for certain transactions, or assess a specific fee or incorporate the 
costs into other fee programs.'' \464\ CAT LLC stated that assessing a 
transaction-based fee to an executing broker and the executing broker 
deciding whether and how to pass-through its costs to clients is ``not 
new or novel.'' \465\ Finally, CAT LLC noted that the Plan Processor 
would provide trade-by-trade data to CAT Executing Brokers, and will 
offer a training program for CAT Executing Brokers to help them 
understand their CAT bills.\466\
---------------------------------------------------------------------------

    \462\ See Virtu Letter at 5.
    \463\ See CAT LLC July 2023 Response Letter at 9. See also id. 
at 5.
    \464\ CAT LLC July 2023 Response Letter at 10. See also id. at 5 
(adding that broker-dealers pass-through fees to customers related 
to Section 31 fees).
    \465\ Id.
    \466\ Id. at 10. See also id. at 5.
---------------------------------------------------------------------------

    In the Commission's view, CAT LLC's definition of ``CAT Executing 
Broker'' is reasonable given that the Executed Share Model is based 
upon the calculation of executed equivalent shares (emphasis 
added),\467\ and the executing brokers are reasonably suited to know 
their own volume and plan for future volume of executed equivalent 
shares to pay the CAT fees. One commenter's suggested approach would 
also result in the assessment of fees on a subset of Industry Members 
--originating brokers--and thus could raise similar allocation concerns 
as those raised by the commenter about the proposed approach.\468\ In 
addition, as discussed below, the Commission agrees with the 
Participants that the ease of administration in using the transaction 
reports to identify the executing broker is an advantage of the 
Proposed Amendment. Given the similar issues with either approach--
either charging the fees to a subset of Industry Members based on 
whether they are the ``CAT Executing Broker'' or the originating 
broker--it is reasonable to choose the less administratively burdensome 
of the two options. Accordingly, the assessment of CAT fees on CAT 
Executing Brokers is reasonable.\469\
---------------------------------------------------------------------------

    \467\ See Notice, supra note 7, 88 FR at 17086.
    \468\ See SIFMA May 2023 Letter at 5, 6.
    \469\ See 17 CFR 242.608(b)(2).
---------------------------------------------------------------------------

    In response to the commenter that questioned CAT LLC's response 
that some of the largest Industry Members are not involved in order 
origination or originate few orders relative to their market 
activity,\470\ the Commission is not relying on this statement by CAT 
LLC and understands that the executing broker and the originating 
broker would be the same in the case of proprietary

[[Page 62650]]

trading activity. Although one commenter suggested that the originating 
broker model should be pursued if it dramatically reduces market-wide 
implementation costs with a marginal increase in CAT costs,\471\ the 
Commission believes that the executing broker model is reasonable. The 
Commission understands the argument that charging originating brokers 
instead of executing brokers would be easier and more cost effective 
for the executing brokers, but it would be at the expense of the 
originating brokers. The Commission also understands that charging 
executing brokers instead of originating brokers is easier and more 
cost effective for the CAT Plan Processor. Using C

[…truncated; see source link]
Indexed from Federal Register on September 12, 2023.

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