July 8, 2020

Volume X, Number 190

July 07, 2020

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July 06, 2020

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SEC Amends CAT NMS Plan

On May 15, the Securities and Exchange Commission adopted amendments to the national market system plan governing the consolidated audit trail (the CAT NMS Plan). The Financial Industry Regulatory Authority (FINRA) and the national securities exchanges that are CAT NMS Plan participants (the Participants) are now required to publish and file with the SEC a complete implementation plan for the Consolidated Audit Trail (CAT) and quarterly progress reports. The reports include financial accountability provisions that establish target deadlines for four critical implementation milestones, and must be approved by the operating committee established by the CAT NMS Plan and submitted to the CEO, president, or an equivalently situated senior officer at each participant.

The SEC sought to improve transparency and financial accountability to the CAT’s implementation.

The amendments will become effective 30 days after publication of the adopting release in the Federal Register.

For more information, the amendments are available here.

©2020 Katten Muchin Rosenman LLPNational Law Review, Volume X, Number 150

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About this Author

Susan Light, Katten Law Firm, Finance Law Attorney, New York
Partner

Susan Light focuses her practice on financial services regulatory matters. She counsels broker-dealers, hedge funds, investment banks and financial services clients on enforcement issues involving the Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA), other self-regulatory organizations (SROs) and state and federal regulatory authorities. She has particular experience related to sales practice issues, financial and operational issues, anti-money laundering, crowdfunding, cybersecurity, and cryptocurrencies.

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212-940-8599
Michael T. Foley, Katten, Lawyer, Finance, FINRA, Chicago
Special Counsel

Michael Foley represents broker-dealers, investment advisers and other financial services industry participants with respect to a broad spectrum of legal and regulatory matters arising under the federal securities laws.

Michael has nearly 20 years of experience in private practice and in-house at both a large, full-service broker-dealer and at an online discount broker-dealer, advising broker-dealers and other financial institutions regarding compliance with the federal securities and commodities laws, and with the regulations of the US Securities and Exchange Commission, the US Commodity Futures Trading Commission and financial industry self-regulatory organizations. 

312-902-5452
Gregory Uffner, Financial Services Attorney, Katten Law Firm
Associate

Gregory Uffner is an associate in the Financial Services practice. 

While in law school, Gregory was an associate editor for the Moot Court Board, a member of the Fordham Urban Law Journal and served as managing editor for the Fordham Sports Law Forum.

212.940.6485