# Seeking Public Input on the

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URL: https://www.frixlaw.com/law-library/documents/agency%3Asec%3A7f9e416b4e428e44

## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

FACT SHEET

Seeking Public Input on the
Consolidated Audit Trail and Other
Audit Trails and Data Sources
On April 16, 2026, the Securities and Exchange Commission issued a concept release to
solicit public comment in support of a comprehensive review of the Consolidated Audit Trail
(CAT) and other audit trails and related data sources currently used in the regulation of U.S.
securities markets.

Background
Effective oversight of the U.S. securities markets by the Commission and by self-regulatory
organizations, including the national securities exchanges and national securities
associations (collectively, the SROs), relies on, among other things, access by regulatory
users to accurate and timely market data. Because the vast majority of securities
transactions in modern markets occur electronically, at high speeds and volumes and
across trading venues, cross-market data plays an important role in that oversight.
Before the implementation of the CAT, cross-market audit trail information had significant
limitations, and analysis of cross-market trading activity was often a cumbersome,
complex, and time-consuming process that was prone to error. To improve the accuracy,
completeness, accessibility, and timeliness of the data available to regulators, the
Commission, in 2012, adopted Rule 613 under the Securities Exchange Act of 1934 to
require the SROs to jointly develop a national market system plan to create, implement,
and maintain the CAT (the “CAT NMS Plan”). The CAT NMS Plan was approved by the
Commission in 2016.

Highlights of the Concept Release
Developments Following Approval of the CAT NMS Plan
There have been a number of developments in the nearly ten years since the CAT NMS
Plan was approved by the Commission, including:
●

The CAT has been implemented, and other audit trails and data sources, like the
Order Audit Trail System (OATS), have been retired.

●

The annual costs of maintaining and operating the CAT have grown well beyond
the Commission’s 2016 estimate, in part because markets have experienced much
higher volumes and more trading activity than anticipated.

U.S. SECURITIES AND EXCHANGE COMMISSION

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FACT SHEET | Seeking Public Input on the Consolidated Audit Trail and Other Audit Trails and Data Sources

●

The Commission has received suggestions from the SROs and other market
participants about potential considerations for, and improvements to, audit trails
and/or related data sources, including petitions for rulemaking related to the
operation and funding of the CAT. In addition, there have also been legal
challenges to the CAT.

Comprehensive Review of the CAT and Other Audit Trails and Related Data Sources
To further consider these developments, the Commission has determined to conduct a
comprehensive review of the CAT and other audit trails and related data sources currently
used by securities regulators.
The concept release solicits comments to aid this comprehensive review, on topics
including, but not limited to, CAT funding and cost management, the regulatory purpose of
the CAT, the structure and governance of the CAT, the design and scope of the CAT, and
the cybersecurity and data privacy of the CAT and other audit trails and related data
sources, as well as comments regarding the appropriate balance between privacy and
confidentiality considerations, civil liberties protections, and regulatory need.
The Commission encourages comment from all interested parties on the general and
specific questions raised in the concept release, as well as on any other aspects of audit
trails and related data sources either currently in use or that should be created. The
Commission also welcomes comments on any costs, burdens, or benefits that may result
from possible regulatory responses related to the items discussed in the concept release
or otherwise raised by commenters.

What’s Next
The concept release will be published on the SEC’s website and in the Federal Register.
The comment period will remain open for 60 days from publication in the Federal Register.

U.S. SECURITIES AND EXCHANGE COMMISSION

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Asec%3A7f9e416b4e428e44. Public record. Not legal advice.