In a letter filed with the US Securities and Exchange Commission (SEC) in response to the Amendment to the National Market System Plan Governing the Consolidated Audit Trail (CAT), the FIA Principal Traders Group (FIA PTG) urged the SEC to reject the latest proposed Funding Model. FIA PTG said the CAT requires a fundamental change to its governance and transparency model. Either it should become an SEC initiative that is subject to public notice and comment and cost/benefit analysis, or Industry Members, including FIA PTG members, deserve representation commensurate with their proposed share of the financial burden.
Additionally, FIA PTG asserted that the overall scope and budget have no checks and balances, and accordingly, despite bearing most of the costs, there will be no opportunity for the public, to review and provide commentary on the development of the annual CAT budget in advance of its implementation.
In summary, FIA PTG said that requiring Industry Members, including FIA PTG members, to incur most of the costs, both ongoing and historical, of a system over which they have no control and data of which they have no access to, is unfair and therefore the Proposal should not be approved.
