Notice2026-01610

Order Granting Exemptive Relief, Pursuant to Section 36(a)(1) of the Securities Exchange Act of 1934 (“Exchange Act”) and Rule 608(e) of Regulation NMS Thereunder, Relating to the Reporting of Responses to Requests for Quotes and Other Solicitation Responses Provided in a Standard Electronic Format, as Required by Section 6.4(d) of the National Market System Plan Governing the Consolidated Audit Trail

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Published
January 27, 2026

Issuing agencies

Securities and Exchange Commission

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<title>Federal Register, Volume 91 Issue 17 (Tuesday, January 27, 2026)</title>
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[Federal Register Volume 91, Number 17 (Tuesday, January 27, 2026)]
[Notices]
[Pages 3572-3574]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-01610]


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SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-104662]


Order Granting Exemptive Relief, Pursuant to Section 36(a)(1) of 
the Securities Exchange Act of 1934 (``Exchange Act'') and Rule 608(e) 
of Regulation NMS Thereunder, Relating to the Reporting of Responses to 
Requests for Quotes and Other Solicitation Responses Provided in a 
Standard Electronic Format, as Required by Section 6.4(d) of the 
National Market System Plan Governing the Consolidated Audit Trail

January 23, 2026.

I. Introduction

    On July 18, 2012, the Securities and Exchange Commission (the 
``Commission'' or the ``SEC'') adopted Rule 613 of Regulation NMS, 
which required the national securities exchanges and national 
securities associations (the ``Participants'') \1\ to

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jointly develop and submit to the Commission a national market system 
plan to create, implement, and maintain the consolidated audit trail 
(``CAT'').\2\ The goal of Rule 613 was to create a modernized audit 
trail system that would provide regulators with timely access to a 
comprehensive set of trading data, thus enabling regulators to more 
efficiently and effectively analyze and reconstruct market events, 
monitor market behavior, conduct market analysis to support regulatory 
decisions, and perform surveillance, investigation, and enforcement 
activities. On November 15, 2016, the Commission approved the national 
market system plan required by Rule 613 (``the CAT NMS Plan'').\3\
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    \1\ The current Participants to the CAT NMS Plan are 24X 
National Exchange LLC, 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., Financial 
Industry Regulatory Authority, Inc., Investors Exchange LLC, Long-
Term Stock Exchange, Inc., MEMX LLC, Miami International Securities 
Exchange LLC, MIAX Emerald, LLC, MIAX PEARL, LLC, MIAX Sapphire, 
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 National, 
Inc., and NYSE Texas, Inc.
    \2\ See Securities Exchange Act Release No. 67457 (July 18, 
2012), 77 FR 45722 (Aug. 1, 2012); 17 CFR 242.613.
    \3\ See Securities Exchange Act Release No. 79318, 81 FR 84696 
(Nov. 23, 2016) (``CAT NMS Plan Approval Order''). Unless otherwise 
noted, capitalized terms are used as defined in the CAT NMS Plan.
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    On May 20, 2024, in response to a request from the Participants,\4\ 
the Commission granted temporary exemptive relief, pursuant to its 
authority under section 36(a)(1) of the Exchange Act,\5\ and Rule 
608(e) of Regulation NMS under the Exchange Act,\6\ from certain 
reporting requirements in section 6.4(d) of the CAT NMS Plan \7\ 
relating to the reporting of bids and/or offers made in response to a 
request for quote (``RFQ'') or other form of solicitation response 
provided in standard electronic format (e.g., FIX) that is not 
``immediately actionable'' (i.e., further action is required by the 
responder providing the quote in order to execute or cause a trade to 
be executed) (``NIA Electronic RFQ Responses'').\8\ Pursuant to the 
Prior Order, this temporary conditional exemptive relief has an 
expiration date of July 31, 2026.\9\
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    \4\ See letter from the Participants to Vanessa Countryman, 
Secretary, Commission, dated Feb. 13, 2024 (the ``2024 Exemption 
Request''), available at: <a href="https://catnmsplan.com/sites/default/files/2024-02/02.13.24-Exemption-Request-Responses-to-Electronic-RFQs.pdf">https://catnmsplan.com/sites/default/files/2024-02/02.13.24-Exemption-Request-Responses-to-Electronic-RFQs.pdf</a>.
    \5\ 15 U.S.C. 78mm(a)(1).
    \6\ 17 CFR 242.608(e).
    \7\ Section 6.4(d) of the CAT NMS Plan describes the type of 
information that the Participants must require Industry Members to 
report to the CAT and when such information must be reported.
    \8\ See Securities Exchange Act Release No. 34-100181, 89 FR 
45715 (May 23, 2024) (``Prior Order'').
    \9\ The Prior Order stated that, as a condition to relief, the 
Participants must provide the Commission a written implementation 
plan on the reporting of NIA Electronic RFQ Responses by July 31, 
2025, and that this implementation plan for the reporting of NIA 
Electronic RFQ Responses must: (1) identify workflows to facilitate 
the reporting of NIA Electronic RFQ Responses; and (2) provide or 
reference published technical specifications to allow for the 
reporting of NIA Electronic RFQ Responses by Industry Members. Id. 
at 45716-17. The exemptive relief granted by this Order does not 
include any conditions.
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    For the reasons set forth below, this Order grants the Participants 
exemptive relief consistent with that previously granted by the 
Commission relating to the reporting of NIA Electronic RFQ Reponses in 
the Prior Order, except without the conditions previously imposed and 
without an expiration date.

II. Discussion and Exemptive Relief

    Section 36(a)(1) of the Exchange Act grants the Commission the 
authority, with certain limitations, to ``conditionally or 
unconditionally exempt any person, security, or transaction . . . from 
any provision or provisions of [the Exchange Act] or of any rule or 
regulation thereunder, to the extent that such exemption is necessary 
or appropriate in the public interest, and is consistent with the 
protection of investors.'' \10\ Under Rule 608(e) of Regulation NMS, 
the Commission may ``exempt from [Rule 608], either unconditionally or 
on specified terms and conditions, any self-regulatory organization, 
member thereof, or specified security, if the Commission determines 
that such exemption is consistent with the public interest, the 
protection of investors, the maintenance of fair and orderly markets 
and the removal of impediments to, and perfection of the mechanism of, 
a national market system.'' \11\
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    \10\ 15 U.S.C. 78mm(a)(1).
    \11\ 17 CFR 242.608(e).
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    After careful consideration, the Commission has determined to grant 
exemptive relief consistent with that previously granted by the 
Commission relating to the reporting of NIA Electronic RFQ Reponses but 
without conditions or time limits. Industry members and Participants 
have continued to devote and expend substantial resources toward the 
ongoing development of CAT. The implementation of electronic recording 
and reporting of NIA Electronic RFQ Responses has proven to be 
particularly challenging. Compliance requires both the sender and 
receiver of the information to determine how to report information to 
the CAT, and this information is not currently captured in a format 
designed to be reported to the CAT. Additionally, the Commission 
received comment letters stating that exemptive relief is ``necessary'' 
for electronic responses to RFQs that cannot be executed by the party 
that receives the RFQ response,\12\ and cautioning that the requirement 
to report RFQ responses that are not actionable would ``involve costly 
manual processes.'' \13\ Also, some Industry Members maintain that the 
reporting of NIA Electronic RFQ Responses is not required by Rule 613 
or the CAT NMS Plan.\14\
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    \12\ See letter to Vanessa Countryman, Secretary, Commission, 
from Howard Meyerson, Managing Director, Financial Information 
Forum, dated Sept. 9, 2024, at 2, available at: <a href="https://www.sec.gov/comments/4-698/4698-518035-1490942.pdf">https://www.sec.gov/comments/4-698/4698-518035-1490942.pdf</a>.
    \13\ See letter to Vanessa Countryman, Secretary, Commission, 
from Howard Meyerson, Managing Director, Financial Information 
Forum, dated Dec. 6, 2024, at 3, available at: <a href="https://www.sec.gov/comments/4-698/4698-558515-1603022.pdf">https://www.sec.gov/comments/4-698/4698-558515-1603022.pdf</a>. See also Letter to Paul S. 
Atkins, Chairman, Securities and Exchange Commission, from Joseph 
Corcoran, Managing Director and Associate General Counsel and Gerald 
O'Hara, Vice President and Assistant General Counsel, Securities 
Industry and Financial Markets Association (``SIFMA''), dated June 
6, 2025, available at: <a href="https://www.sec.gov/comments/4-698/4698-610487-1785814.pdf">https://www.sec.gov/comments/4-698/4698-610487-1785814.pdf</a> (stating that the SEC should review all of its 
orders granting temporary exemptive relief from CAT reporting 
requirements with a view to making them permanent); letter to Paul 
S. Atkins, Chairman, Securities and Exchange Commission, from Joanna 
Mallers, Secretary, FIA Principal Traders Group, dated June 26, 
2025, available at: <a href="https://www.sec.gov/comments/4-853/4853-618547-1815754.pdf">https://www.sec.gov/comments/4-853/4853-618547-1815754.pdf</a> (stating that the Commission should codify its orders 
granting temporary exemptive relief for certain CAT requirements 
that are unreasonable or burdensome).
    \14\ See, e.g., letter to Vanessa Countryman, Secretary, 
Securities and Exchange Commission, from Joseph Corcoran, Managing 
Director and Associate General Counsel and Ellen Greene, Managing 
Director, Equities & Options Market Structure, SIFMA, and Howard 
Meyerson, Managing Director, FIF, dated July 31, 2023, available at: 
<a href="https://www.sec.gov/comments/4-698/4698-238359-498762.pdf">https://www.sec.gov/comments/4-698/4698-238359-498762.pdf</a>; letter to 
Vanessa Countryman, Secretary, Securities and Exchange Commission, 
from Howard Meyerson, Managing Director, Financial Information 
Forum, dated June 1, 2023, available at <a href="https://fif.com/index.php/working-groups/category/271-comment-letters?download=2730:fif-letter-to-the-sec-on-cat-reporting-for-non-executable-rfq-responses&start=60&view=category">https://fif.com/index.php/working-groups/category/271-comment-letters?download=2730:fif-letter-to-the-sec-on-cat-reporting-for-non-executable-rfq-responses&start=60&view=category</a>.
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    After further evaluation and in light of the implementation 
challenges, the Commission has determined that relief from Section 
6.4(d) of the CAT NMS Plan for the recording and reporting of NIA 
Electronic RFQ Responses is appropriate because the regulatory value of 
this information does not justify the difficulty and costs associated 
with collecting and reporting such information. In addition, regulators 
will still have insight into the RFQ process, because any follow-up 
order activity subsequent to the transmission of NIA

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Electronic RFQ Responses that results in an execution, will be reported 
to the CAT.
    As provided in the Prior Order, the NIA Electronic RFQ Responses 
that are subject to this exemptive relief: (1) are those that satisfy 
the definition of an ``order'' as defined in Rule 613(j)(8) and the CAT 
NMS Plan; \15\ (2) do not include RFQ responses that were required to 
be reported commencing in Phase 2c and Phase 2d; \16\ and (3) do not 
include activity that is subject to section 6.3(g) of the CAT NMS 
Plan.\17\
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    \15\ The CAT NMS Plan defines ``order,'' by reference to Rule 
613(j)(8), to include ``[a]ny order received by a member of a 
national securities exchange or national securities association from 
any person; (b) any order originated by a member of a national 
securities exchange or national securities association; or (c) any 
bid or offer.'' Section 1.1. of the CAT NMS Plan; 17 CFR 
242.613(j)(8).
    \16\ See 2024 Exemption Request, at 3-4. As explained by the 
Participants, in April 2020 the Commission granted conditional 
exemptive relief to allow for the implementation of phased Industry 
Member reporting to the CAT across five phases, and this exemptive 
relief did not specifically address NIA Electronic RFQ Responses. 
Id.; Securities Exchange Release No. 88702 (Apr. 20, 2020), 85 FR 
23075 (Apr. 24, 2020) (``Phased Reporting Exemption''). Pursuant to 
the Phased Reporting Exemption, any bid or offer in response to a 
request for quote or other form of solicitation response provided in 
standard electronic format (e.g., FIX) that required no further 
action by the responder providing the quote in order to execute or 
cause a trade to be executed was reportable in Phase 2c for equities 
and in Phase 2d for options. See Phased Reporting Exemption at 
23079; see also 2024 Exemption Request, at 3-4.
    \17\ See 2024 Exemption Request, at 4-5; Section 6.3(g) of the 
CAT NMS Plan (``Verbal Activity, Floor, and Upstairs Activity''). 
Section 6.3(g) of the CAT NMS Plan identifies certain categories of 
data that shall not be reportable to the Central Repository: (i) 
until July 31, 2030, floor broker verbal announcements of firm 
orders on an exchange that are otherwise reported as systematized 
orders; (ii) until July 31, 2030, market maker verbal announcements 
of firm quotes on an exchange trading floor; (iii) telephone 
discussions between an Industry Member and a client that may involve 
firm bid and offer communications; and (iv) unstructured electronic 
and verbal communications that are not currently captured by 
Industry Member order management or execution systems (e.g., 
electronic chats, text messages). See also Securities Exchange Act 
Release No. 103275 (June 16, 2025), 90 FR 26337 (June 20, 2025) 
(``Order Approving an Amendment to the National Market System Plan 
Governing the Consolidated Audit Trail, as Modified by the 
Commission, Regarding the Reporting of Certain Verbal Activity, 
Floor and Upstairs Activity''). With respect to activity subject to 
section 6.3(g) of the CAT NMS Plan, to the extent that NIA 
Electronic RFQ Responses are unstructured electronic communications 
that are not currently captured by Industry Member order management 
or execution systems, section 6.3(g)(iv) of the CAT NMS Plan already 
makes such messages not reportable to the CAT and thus exemptive 
relief is not necessary.
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    Based on the foregoing, pursuant to section 36(a)(1) of the 
Exchange Act, it is appropriate in the public interest and is 
consistent with the protection of investors, and, pursuant to Rule 
608(e), it is consistent with the public interest, the protection of 
investors, the maintenance of fair and orderly markets and the removal 
of impediments to, and the perfection of, the mechanisms of a national 
market system, to grant exemptive relief from the requirement in 
section 6.4(d) of the CAT NMS Plan for the recording and reporting of 
NIA Electronic RFQ Responses.\18\ This exemptive relief is intended to 
mirror the relief granted in the Prior Order, except without the 
conditions previously imposed and without an expiration date. When this 
Order takes effect, the relief granted therein will supersede the 
relief granted in the Prior Order.
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    \18\ To the extent that the Participants are availing themselves 
of exemptive relief from a CAT NMS Plan requirement, such 
requirement shall not be included in the requirements for the 
Financial Accountability Milestones. See CAT NMS Plan, at section 
1.1 (``Financial Accountability Milestone'' definition).
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IV. Conclusion

    As discussed above, it is appropriate to grant exemptive relief 
that exempts each Participant from the requirement in section 6.4(d) of 
the CAT NMS Plan for each Participant, through its Compliance Rule, to 
require its Industry Members to record and electronically report to the 
Central Repository NIA Electronic RFQ Responses.
    Accordingly, it is hereby ordered, pursuant to section 36(a)(1) of 
the Exchange Act,\19\ and Rule 608(e) of the Exchange Act \20\ that the 
Participants are granted an exemption from the requirement in section 
6.4(d) of the CAT NMS Plan that requires each Participant, through its 
Compliance Rule, to require its Industry Members to record and 
electronically report to the Central Repository bids and/or offers made 
in response to a request for quote or other form of solicitation 
response provided in standard electronic format (e.g., FIX) that is not 
``immediately actionable'' (i.e., further action is required by the 
responder providing the quote in order to execute or cause a trade to 
be executed).
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    \19\ 15 U.S.C. 78mm(a)(1).
    \20\ 17 CFR 242.608(e).

    By the Commission.
Stephanie J. Fouse,
Assistant Secretary.
[FR Doc. 2026-01610 Filed 1-26-26; 8:45 am]
BILLING CODE 8011-01-P


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Indexed from Federal Register on January 27, 2026.

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