FIA PTG submitted a letter today in support of comments by the Securities Industry and Financial Markets Association (SIFMA) on proposed fees for industry members for the Consolidated Audit Trail (CAT).
The CAT funding model should have been the result of a collaborative exercise that included all of the impacted industry participants. Instead, only plan participants had input. As SIFMA noted, the CAT “is being created by and for the benefit of the plan participants.” Yet the funding model requires broker-dealers and ATSs to bear nearly 90% of the costs.
The plan participants clearly have a conflict of interest when it comes to determining how much of the cost of this endeavor they should bear. Since broker-dealers, like many FIA PTG members, already provide plan participants with a significant amount of regulatory funding through various membership and regulatory fees, having representation during the development of the funding model would have certainly been helpful in understanding the justification for charging market participants at all – not to mention the rationale for the ultimate structure proposed.
