FIA PTG sent a comment letter to the SEC today raising concerns about amendments to the previously proposed fee schedule rule changes filed by the self-regulatory organizations (SROs) that are the plan participants to the Consolidated Audit Trail (CAT).
In two previous letters (FIA PTG lists concerns with CAT fee structure and FIA PTG raises cybersecurity concerns with CAT), FIA PTG raised concerns including: the cost allocation methodology, the use of inconsistent metrics, the disproportionate impact on options market-makers, the lack of transparency, conflicts of interest, and the governance of the CAT NMS, LLC.
While FIA PTG appreciates that in the amended proposals the plan participants have made changes to the funding model for market-makers, the amendments fail to address most of the issues that exist with the proposed fee structure.
The letter is available under Resources on the right.
