81120 Federal Register / Vol. 89, No. 194 / Monday, October 7, 2024 / Notices 

1 15 U.S.C. 78k–1(a)(3). 

2 17 CFR 242.608. 

3 In July 2012, the Commission adopted Rule 613 

of Regulation NMS, which required the Participants 

to jointly develop and submit to the Commission a 

national market system plan to create, implement, 

and maintain a consolidated audit trail (the 

‘‘CAT’’). See Securities Exchange Act Release No. 

67457 (July 18, 2012), 77 FR 45722 (Aug. 1, 2012 

(‘‘Rule 613 Adopting Release’’); 17 CFR 242.613. On 

November 15, 2016, the Commission approved the 

CAT NMS Plan. See Securities Exchange Act 

Release No. 78318 (Nov. 15, 2016), 81 FR 84696 

(Nov. 23, 2016) (‘‘CAT NMS Plan Approval Order’’). 

The CAT NMS Plan is Exhibit A to the CAT NMS 

Plan Approval Order. See CAT NMS Plan Approval 

Order, at 84943–85034. 

4See Letter from Brandon Becker, CAT NMS Plan 

Operating Committee Chair, to Vanessa 

Countryman, Secretary, Commission, dated March 

27, 2024, available at https://catnmsplan.com/sites/ 

default/files/2024-03/03.27.24-Proposed-CAT-NMSPlan-Amendment-Cost-Savings-Amendment.pdf. 

MIAX Sapphire, LLC was not a Participant to the 

CAT NMS Plan when the Proposal was originally 

filed, but the Participants filed an immediatelyeffective amendment to the CAT NMS Plan on July 

30, 2024 to add MIAX Sapphire, LLC as a 

Participant. See Securities Exchange Act Release 

No. 100631 (July 31, 2024), 89 FR 64011 (Aug. 6, 

2024). 

5See Securities Exchange Act Release No. 99938 

(Apr. 10, 2024), 89 FR 26983 (Apr. 16, 2024) 

(‘‘Notice’’). Comments received in response to the 

Notice can be found on the Commission’s website 

at https://www.sec.gov/comments/4-698/4-698- 

d.htm. 

6 17 CFR 242.608(b)(2)(i). 

7See Securities Exchange Act Release No. 100530 

(July 15, 2024), 89 FR 58838 (July 19, 2024). 

8See Letter from Brandon Becker, CAT NMS Plan 

Operating Committee Chair, to Vanessa 

Countryman, Secretary, Commission, dated Sept. 

20, 2024, available at https://www.sec.gov/ 

comments/4-698/4698-522995-1501362.pdf. 

9See Letter from Howard Meyerson, Managing 

Director, FIF, to Commission (May 7, 2024); Letter 

from Ellen Greene, Managing Director, Equities & 

Options Market Structure, and Joseph Corcoran, 

Managing Director, Associate General Counsel, 

SIFMA, to Vanessa Countryman, Secretary, 

Commission (May 31, 2024); Letter from Jeffrey S. 

Davis, Senior Vice President, Principal Deputy 

General Counsel, Nasdaq, Inc., to Vanessa 

Countryman, Secretary, Commission (July 1, 2024). 

of information; (c) ways to enhance the 

quality, utility, and clarity of the 

information collected; and (d) ways to 

minimize the burden of the collection of 

information on respondents, including 

through the use of automated collection 

techniques or other forms of information 

technology. Consideration will be given 

to comments and suggestions submitted 

by December 6, 2024. 

An agency may not conduct or 

sponsor, and a person is not required to 

respond to, a collection of information 

under the PRA unless it displays a 

currently valid OMB control number. 

Please direct your written comments 

to: Austin Gerig, Director/Chief Data 

Officer, Securities and Exchange 

Commission, c/o Oluwaseun Ajayi, 100 

F Street NE, Washington, DC 20549 or 

send an email to: PRA_Mailbox@

sec.gov. 

Dated: October 2, 2024. 

Vanessa A. Countryman, 

Secretary. 

[FR Doc. 2024–23150 Filed 10–4–24; 8:45 am] 

BILLING CODE 8011–01–P 

SECURITIES AND EXCHANGE 

COMMISSION 

[Release No. 34–101225; File No. 4–698] 

Joint Industry Plan; Notice of Filing of 

Partial Amendment No. 1 to an 

Amendment to the National Market 

System Plan Governing the 

Consolidated Audit Trail Regarding 

Cost Savings Measures 

October 1, 2024. 

On March 27, 2024, and pursuant to 

Section 11A(a)(3) of the Securities 

Exchange Act of 1934 (the ‘‘Exchange 

Act’’) 1 and Rule 608 of Regulation NMS 

thereunder,2 BOX Exchange LLC, Cboe 

BYX Exchange, Inc., Cboe BZX 

Exchange, Inc., Cboe C2 Exchange, Inc., 

Cboe EDGA Exchange, Inc., Cboe EDGX 

Exchange, Inc., Cboe Exchange, Inc., 

The Financial Industry Regulatory 

Authority, Inc., Investors’ Exchange 

LLC, Long-Term Stock Exchange, Inc., 

MEMX LLC, Miami International 

Securities Exchange LLC, MIAX 

Emerald, LLC, MIAX PEARL, LLC, 

Nasdaq BX, Inc., Nasdaq GEMX, LLC, 

Nasdaq ISE, LLC, Nasdaq MRX, LLC, 

Nasdaq PHLX LLC, The Nasdaq Stock 

Market LLC, New York Stock Exchange 

LLC, NYSE American LLC, NYSE Arca, 

Inc., NYSE Chicago, Inc., and NYSE 

National, Inc. (‘‘the Participants’’) filed 

with the Securities and Exchange 

Commission (the ‘‘Commission’’ or the 

‘‘SEC’’) proposed amendments to the 

national market system plan governing 

the consolidated audit trail (the ‘‘CAT 

NMS Plan’’) 3 that were designed to 

implement certain costs saving 

measures (the ‘‘Proposed Cost Savings 

Amendments’’).4 The Proposed Cost 

Savings Amendments were published 

for comment in the Federal Register on 

April 16, 2024.5 On July 15, 2024, the 

Commission instituted proceedings 

pursuant to Rule 608(b)(2)(i) of 

Regulation NMS,6 to determine whether 

to disapprove the Proposed Cost Savings 

Amendments or to approve the 

Proposed Cost Savings Amendments 

with any changes or subject to any 

conditions the Commission deems 

necessary or appropriate after 

considering public comment (the 

‘‘OIP’’).7

On September 20, 2024, the 

Participants submitted a letter to 

propose certain revisions to the 

Proposed Cost Savings Amendments 

and to respond to issued discussed in 

the OIP.8 Sections I, II, and III below, 

which were substantially prepared by 

CAT LLC on behalf of the Participants, 

contain a description of the revisions to 

the Proposed Cost Savings 

Amendments, additional details 

regarding the Participants’ calculation of 

estimated cost savings, and responses 

prepared by the Participants to the OIP, 

respectively. In addition, the 

Participants filed Exhibit A, which sets 

forth the cumulative changes proposed 

to be made to the CAT NMS Plan, and 

Exhibit B, which sets forth the proposed 

additional revisions to the changes in 

the Proposed Cost Savings 

Amendments. The Commission is 

publishing this notice to solicit 

comments on the additional revisions to 

the Proposed Cost Savings Amendments 

from interested persons. 

I. Revisions to the Proposed Cost 

Savings Amendments 

CAT LLC was both surprised and 

disappointed by the Commission’s 

decision to institute proceedings on the 

Proposed Cost Savings Amendments, 

which will delay or ultimately impede 

CAT LLC’s ability to achieve more than 

$20 million in annual cost savings. All 

commenters strongly favored the 

Proposed Cost Savings Amendments.9

The Commission did not receive any 

comments opposing the proposed 

amendments. 

While the Commission does not bear 

any CAT costs, the Commission’s 

objective should be to ensure the CAT 

achieves its regulatory objectives in an 

efficient and cost-effective manner. The 

immense costs of operating the CAT— 

estimated at $213 million in 2024—are 

driven by the strict requirements in the 

CAT NMS Plan to process and store 

record data volumes in accordance with 

complex reporting and linkage 

requirements, within the narrow 

timeframes required by the SEC. CAT 

LLC and the Plan Processor have put 

significant effort into reducing CAT 

costs that are within their control given 

these strict requirements, but many 

additional cost savings measures require 

Commission action to permit their 

implementation. 

After discussions with the Staff, CAT 

LLC is withdrawing the proposal to 

provide an interim CAT-Order-ID on an 

‘‘as requested’’ basis, as opposed to on 

a continuous basis, which would have 

resulted in approximately $2 million in 

annual cost savings. With these changes, 

CAT LLC strongly urges the 

Commission to approve the Proposed 

Cost Savings Amendments without 

further delay. 


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10For a description of these requirements, see OIP 

at 58839–40. 

11As described in the SRO Letter, only market 

maker quotes that are reported to CAT as quote 

events would be affected by the proposal. Market 

maker quotes reported to CAT as order events will 

not be impacted by this proposal and will continue 

to receive all enrichments and be fully available to 

regulatory users in DIVER. See SRO Letter at 7. 

12An ‘‘Options Market Maker’’ is ‘‘a broker-dealer 

registered with an exchange for the purpose of 

making markets in options contracts on the 

exchange.’’ Section 1.1 of the CAT NMS Plan. A 

‘‘Listed Option’’ is defined as having ‘‘the meaning 

set forth in Rule 600(b)(35) of Regulation NMS.’’ 

See id. Rule 600(b)(35) has since been redesignated 

as Rule 600(b)(43), which defines a ‘‘Listed Option’’ 

as ‘‘any option traded on a registered national 

securities exchange or automated facility of a 

national securities association.’’ 17 CFR 

242.600(b)(43). 

13See Section 6.4(d)(iii) of the CAT NMS Plan 

(describing ‘‘the reporting obligations of an Options 

Market Maker with regard to its quotes in Listed 

Options’’). See also CAT Alert 2020–03, Options 

Market Maker Quote Sent Time (June 4, 2020). 

14See Section 5.1 of the CAT Reporting Technical 

Specifications for Plan Participant v. 10r.21 [sic] 

(Apr. 15, 2024), https://www.catnmsplan.com/sites/ 

default/files/2024-04/04.15.2024-CAT_Reporting_

Technical_Specifications_for_Participants_4.1.0- 

r21.pdf. 

15For reference, see Appendix B–1 (describing 

data ingestion error codes) and Appendix B–3 

(describing linkage validation error codes) of the 

CAT Reporting Technical Specifications for Plan 

Participant v.10r.21 [sic] (Apr. 15, 2024). 

A. Processing, Storage, and Query 

Requirements for Options Market Maker 

Quotes in Listed Options 

The CAT NMS Plan currently 

contains broad requirements relating to 

the processing, storage, and querying of 

Option Market Maker quotes in Listed 

Options.10 The Proposed Cost Savings 

Amendments would save approximately 

$20 million annually by changing 

certain processing, query, and storage 

requirements that would otherwise 

apply to Options Market Maker quotes 

in Listed Options.11 These changes 

would significantly reduce the costs of 

the CAT with limited regulatory impact. 

The vast majority of Options Market 

Maker quote lifecycles do not involve 

any execution or allocation and 

Participant regulatory users very rarely 

access such data. Options Exchanges 

would continue to report Options 

Market Maker quotes in Listed Options 

in the same manner they do today, but 

the Plan Processor would only ingest, 

perform basic data validations, and store 

such data. Unlinked data would remain 

accessible to regulators by T+1 at 12:00 

p.m. Eastern Time. 

Based on discussions with the Staff, 

CAT LLC is proposing several revisions 

to the Proposed Cost Savings 

Amendments. 

First, CAT LLC proposes to revise the 

Proposed Cost Savings Amendments to 

replace any proposed references to 

‘‘Options Market Maker Quotes in 

Listed Options,’’ which is not a 

separately defined term in the CAT 

NMS Plan, with ‘‘Options Market Maker 

quotes in Listed Options’’.12 Relatedly, 

to eliminate potential confusion 

regarding the intended scope of the 

proposal, CAT LLC proposes to 

eliminate the phrase ‘‘and related 

Reportable Events’’. CAT LLC believes 

that the meaning of Options Market 

Maker quotes in Listed Options is well 

understood by CAT Reporters as it has 

been the basis for CAT reporting since 

the inception of the CAT.13 Specifically, 

as described in Section 5.1 (Market 

Maker Quotes) of the Plan Participant 

Technical Specifications, there are two 

types of events used to report Options 

Market Maker quotes in Listed Options: 

• Quote Event: Used to report a new 

quote or a quote replacement. When a 

quote is replaced, the Original Quote ID 

will identify the quote being replaced, 

and the Quote ID will provide the new 

ID for the updated and replaced quote 

(or note in the event that the market 

maker can only have one quote active at 

any given time). 

• Quote Cancel: Reported when a 

quote is canceled.14

Accordingly, under the proposed 

amendments, Option Quote (OQ) and 

Option Quote Cancel (OQC) events will 

not be subject to any requirement to link 

and create an order lifecycle, and will 

not undergo any linkage validation, 

linkage feedback, or lifecycle 

enrichment processing. 

Relatedly, trades resulting from an 

Options Market Maker quote are 

reported to the CAT by Plan Participants 

using Option Trade (OT) events. OT 

events will continue to be subject to the 

requirement to link and create an order 

lifecycle, and will undergo linkage 

validation, linkage feedback, and 

lifecycle enrichment processing. 

However, given the proposal to 

eliminate linkage requirements related 

to OQ and OQC events, when an 

Options Market Maker quote is on one 

side of an OT event, the quote side of 

the OT event will not be linked to the 

Options Market Maker quote via the 

linkage process; instead, a single event 

lifecycle will be created that contains 

only the quote side of the OT event. 

Regulators, however, will be able to 

readily identify the Options Market 

Maker quote executed in an OT event 

via the quoteID field on the side of the 

OT event involving the Options Market 

Maker quote. In addition, the side of the 

OT event that does not involve an 

Options Market Maker quote would be 

linked with the relevant order and 

would include the order lifecycle 

related to such order, and would be 

subject to all lifecycle enrichment 

processing. 

Second, CAT LLC proposes to revise 

the Proposed Cost Savings Amendments 

to clarify that the Plan Processor would 

continue to perform ingestion validation 

on Options Market Maker quotes (but 

would stop performing linkage 

validation).15

Third, CAT LLC proposes to revise 

the Proposed Cost Savings Amendments 

to provide that, upon request of the SEC 

or any Participant, the Plan Processor 

will provide the business and technical 

requirements needed to re-create the 

eliminated enrichments, as well as the 

code required to derive any eliminated 

data elements from the unlinked data. 

As revised, new Section 3.4 of 

Appendix D would state: 

3.4 Requirements for Options Market Maker 

Quotes in Listed Options 

The provisions of this section shall govern 

the processing and storage of Options Market 

Maker quotes in Listed Options and shall 

override any conflicting provisions in the 

CAT NMS Plan, this Appendix D, or 

Exchange Act Rule 17a–1. 

Options Market Maker quotes in Listed 

Options must be reported to the Central 

Repository as provided under Section 

6.4(d)(iii) of the CAT NMS Plan. This data 

will undergo ingestion validation only and 

such unlinked data will be made available to 

regulators by T+1 at 12:00 p.m. Eastern Time. 

Options Market Maker quotes in Listed 

Options will not be subject to any 

requirement to link and create an order 

lifecycle, and will not undergo any linkage 

validation, linkage feedback, or lifecycle 

enrichment processing, but will undergo 

ingestion validation. Options Market Maker 

quotes in Listed Options will be accessible 

through BDSQL and Direct Read interfaces 

only and will not be accessible through the 

online targeted query tool. 

Upon request of the SEC or any Participant, 

the Plan Processor will provide the business 

and technical requirements needed to recreate the eliminated enrichments, as well as 

the code (which is unique to the Plan 

Processor’s linkage implementation) existing 

as of the effective date of this provision used 

to derive the eliminated enrichments. The 

Plan Processor will not maintain the business 

and technical requirements and the code 

following the effective date of this provision, 

but it will retain a copy so that they may be 

provided to any regulators that might request 

them in the future. 

In addition, as noted in the Proposed 

Cost Savings Amendments, CAT LLC 

proposes to amend Section 3, Section 

6.1, and Section 8.1.1 of Appendix D of 

the CAT NMS Plan to include crossreferences to new Section 3.4 of 

Appendix D. Consistent with the 

revisions discussed above, references to 

‘‘Options Market Maker Quotes in 

Listed Options and related Reportable 

Events’’ in Section 3, Section 6.1, and 


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16See Section 6.5(b)(i) and Appendix D, Section 

1.4 of the CAT NMS Plan. 

17Exhibit A of the Proposed Cost Savings 

Amendments previously referred to ‘‘interim raw 

unprocessed data’’; the text of Exhibit A has been 

clarified to refer to ‘‘raw unprocessed data’’. 

18CAT Data is currently stored in three storage 

tiers: S3 Frequent Access, S3 Infrequent Access, 

and S3 Instant Archive Access. Data files that are 

either new or that have recently been read by 

regulatory users are stored in S3 Frequent Access. 

If a file is not read by a regulatory user for 30 days, 

then it moves to S3 Infrequent Access. Similarly, if 

a file is not read by a regulatory user for 90 days, 

then it moves to S3 Archive Instant Access. The 

Plan Processor currently anticipates that archived 

data would be restored to the S3 Frequent Access 

tier. Storage tiers are subject to change based on 

future technology developments and product 

offerings. 

19The Proposed Cost Savings Amendments 

inadvertently referred to Section 6.5(d)(i); however, 

Exhibit A of the Proposed Cost Savings 

Amendments accurately reflected the addition of 

the phrase ‘‘subject to the exceptions in Section 6.3 

of Appendix D’’ to Section 6.5(b)(i) as intended. 

20See Exchange Act Release No. 98848 (Nov. 2, 

2023), 88 FR 77128 (Nov. 8, 2023) (granting 

exemptive relief from the requirement set forth in 

appendix D, section 6.1 of the CAT NMS Plan that 

lifecycle linkages be created by T+1 at noon ET). 

21Exchange Act Release No. 95234 (July 8, 2022), 

87 FR 42247, 42248 (July 14, 2022). 22OIP at 58847. 23See Proposed Cost Savings Amendments at 2 

n.5. 

Section 8.1.1 of Appendix D have been 

revised to ‘‘Options Market Maker 

quotes in Listed Options’’. 

B. Storage for Raw Unprocessed Data 

and Interim Operational Copies of CAT 

Data Older Than 15 Days 

The CAT NMS Plan currently requires 

CAT Data to be ‘‘directly available and 

searchable electronically without 

manual intervention for at least six 

years’’ and within certain query tool 

response times.16 The Proposed Cost 

Savings Amendments would save 

approximately $1 million annually by 

permitting the Plan Processor to move 

raw unprocessed data (i.e., as-submitted 

data) and interim operational data older 

than 15 days to a more cost-effective 

storage tier that is optimized for 

infrequent access. In each case, 

retrieving such data for regulators 

would require some ‘‘manual 

intervention’’ by the Plan Processor. 

As described in the Proposed Cost 

Savings Amendments, when a regulator 

queries CAT data, the CAT always 

provides results to the user based on the 

latest, most current version of the data. 

Accordingly, raw unprocessed data and 

interim operational data older than 15 

days do not provide any regulatory 

value after the final corrected data 

version is delivered by T+5 at 8:00 a.m. 

ET. 

Based on discussions with the Staff, 

CAT LLC proposes to amend the 

Proposed Cost Savings Amendments to 

clarify the scope of affected data.17 In 

addition, CAT LLC proposes to clarify 

that the Plan Processor will restore 

archived data to an accessible storage 

tier upon request to the CAT Help Desk 

by an authorized regulatory user from 

the Participants or a senior officer from 

the SEC.18 Finally, CAT LLC proposes to 

clarify that ‘‘Interim Operational Data’’ 

does not include processed data relating 

to Options Market Maker quotes in 

Listed Options made available to 

regulators by T+1 at 12:00 p.m. ET. As 

revised, new Section 6.3 of Appendix D 

would state: 

6.3 Exceptions to Data Availability 

Requirements 

Notwithstanding any other provision of the 

CAT NMS Plan, this Appendix D, or 

Exchange Act Rule 17a–1, the following 

types of data may be retained in an archive 

storage tier. Archived data is not directly 

available and searchable electronically 

without manual intervention and will not be 

subject to any query tool performance 

requirements until it is restored to an 

accessible storage tier. The Plan Processor 

will restore archived data to an accessible 

storage tier upon request to the CAT Help 

Desk by an authorized regulatory user from 

the Participants or a senior officer from the 

SEC. 

• Raw Unprocessed Data older than 15 

days. ‘‘Raw Unprocessed Data’’ means data 

that has been ingested by the Plan Processor 

and made available to regulators prior to 

12:00 p.m. Eastern Time on T+1. 

• Interim Operational Data older than 15 

days. ‘‘Interim Operational Data’’ means all 

processed, validated and unlinked data made 

available to regulators by T+1 at 12:00 p.m. 

ET and all iterations of processed data made 

available to regulators between T+1 and T+5, 

but excludes the final version of corrected 

data that is made available at T+5 at 8:00 a.m. 

ET. For the avoidance of doubt, ‘‘Interim 

Operational Data’’ does not include 

processed data relating to Options Market 

Maker quotes in Listed Options made 

available to regulators by T+1 at 12:00 p.m. 

ET. 

• All submission and feedback files older 

than 15 days. 

In addition, as noted in Exhibit A of 

the Proposed Cost Savings 

Amendments, CAT LLC proposes to add 

the phrase ‘‘subject to the exceptions in 

Section 6.3 of Appendix D’’ to Section 

6.5(b)(i) 19 and Section 1.4 of Appendix 

D. 

C. Provision of an Interim CAT-Order-ID 

on an ‘‘As Requested’’ Basis 

The CAT NMS Plan currently requires 

the Plan Processor to provide an interim 

CAT- Order-ID by T+1 at 9 p.m. ET, 

even where no regulatory need exists.20

With respect to this requirement, the 

Commission has previously invited the 

Participants ‘‘to develop alternative 

solutions that achieve the regulatory 

goals of Rule 613 and the CAT NMS 

Plan in a more cost- effective manner,’’ 

noting that ‘‘the Commission 

emphasizes its willingness to consider 

such alternative solutions in the form of 

a proposed CAT NMS Plan 

amendment.’’ 21

CAT LLC originally proposed to 

provide an interim CAT-Order-ID on an 

‘‘as requested’’ basis, which would have 

saved approximately $2 million 

annually. This alternative solution 

would have preserved the Commission’s 

ability to obtain an interim CAT-OrderID promptly upon request, while 

avoiding the substantial cost of 

delivering an interim CAT-Order-ID on 

a regular ongoing basis even where no 

regulatory need exists. CAT LLC would 

have added a separate line item to its 

budget to reflect costs attributable to 

SEC requests to generate an interim 

CAT-Order-ID. 

However, after discussions with the 

Staff, CAT LLC is withdrawing this 

proposal. Accordingly, the prior 

changes to Section 6.1 of Appendix D 

relating to this proposal have been 

eliminated. The Participants continue to 

believe that the approximate $2 million 

in annual savings associated with the 

proposal substantially outweigh the 

minimal regulatory impact. Subject to 

further discussions with the Staff, the 

Participants will consider whether to repropose this proposal in a future cost 

savings amendment. 

II. Additional Details Regarding 

Calculation of $21 Million in Estimated 

Annual Savings 

The Commission requested 

‘‘additional details and underlying 

calculations used to estimate the cost 

savings as well as information on the 

costs to the Plan Processor of 

implementing each element of each of 

the proposed amendments (e.g., some 

amendments would require coding 

changes, which would impose 

costs).’’ 22

The Proposed Cost Savings 

Amendments and the SRO Letter 

include detailed information regarding 

how the cost savings estimates were 

calculated, which CAT LLC is further 

supplementing below. As previously 

described, all cost savings estimates are 

based on reasonable assumptions 

related to, among other factors, the 

current state and costs of CAT 

operations; current CAT NMS Plan 

requirements; reporting by Participants, 

Industry Members and market data 

providers; observed data rates and 

volumes; current discounts, 

reservations, and cost savings plans; and 

associated cloud fees.23 CAT LLC 


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24Specific to storage cost estimates, S3 Intelligent 

Tier storage fees in production are allocated at a 

ratio of 1 (S3 Frequent Access): 1 (S3 Infrequent 

Access): 8 (S3 Archive Instant Access). This ratio 

describes the current percentage distribution of data 

files between storage tiers, which is driven by 

regulatory usage. Data files that are either new or 

that have recently been read by regulatory users are 

stored in S3 Frequent Access. If a file is not read 

by a regulatory user for 30 days, then it moves to 

S3 Infrequent Access. Similarly, if a file is not read 

by a regulatory user for 90 days, then it moves to 

S3 Archive Instant Access. Based on current 

observed regulatory usage, the Plan Processor’s 

storage cost model is based on a 1:1:8 ratio across 

the S3 storage tiers. If regulatory users begin to read 

more older data files, then those files would be 

moved up to S3 Frequent Access, and the 1:1:8 ratio 

between the S3 storage tiers would change. Because 

each S3 storage tier has its own cost-per-petabyte 

of data, any change in the 1:1:8 ratio based on 

regulatory usage would affect storage costs. 

25The $2.2 million estimate was calculated by 

multiplying (×) the cost of DIVER-specific ETL jobs 

for Options Market Maker quotes, which is 

approximately $13,500 per day, by (y) a 65 percent 

allocation of compute time toward Options Market 

Maker quotes for Participant options data and 

multiplying that result by (z) 252 trading days in 

a year. 

26The $600,000 estimate was calculated by 

multiplying (×) the total storage of DIVER-specific 

copies, which is 0.0542 petabytes per day by (y) a 

90 percent allocation of storage toward Options 

Market Maker quotes based on record volume and 

multiplying that result by (z) 252 trading days in 

a year. 

27The affected data currently represents 

approximately 52% of the daily storage footprint in 

CAT. Specifically, raw unprocessed data (i.e., assubmitted data) represents approximately 16% of 

the daily storage footprint, and interim operational 

copies (i.e., T+1 12 p.m. ET, T+1 9 p.m. ET, and 

associated DIVER copies) represent approximately 

36% of the daily storage footprint. 

believes that the cost savings estimates 

and assumptions are reasonable and 

provide an adequate basis for the 

Commission to evaluate the costs and 

benefits of the Cost Savings 

Amendments. 

One-time implementation costs are 

expected to be minimal relative to 

overall cost savings. Implementation 

costs may vary based on various factors, 

including the details of any 

requirements in any final amendment 

approved by the Commission and any 

changes in labor costs. One-time 

implementation costs will generally 

consist of Plan Processor labor costs 

associated with coding and software 

development, as well as any related 

cloud fees associated with the 

development, testing and load testing of 

the proposed changes. Ongoing 

operational costs, other than cloud 

hosting costs, will not be affected by the 

proposed amendments. 

1. Processing, Storage, and Query 

Requirements for Options Market Maker 

Quotes in Listed Options: Estimated 

Annual Savings of $20 Million 

The Proposed Cost Savings 

Amendments would save approximately 

$20 million annually by changing 

certain processing, query, and storage 

requirements that would otherwise 

apply to Options Market Maker quotes 

in Listed Options. 

Processing Requirements. The Plan 

Processor estimates that approximately 

$12 million in savings would be 

attributable to linkage processing and 

data processing reductions, assuming 22 

processing days per month for a total of 

264 processing days in a year and based 

on data volumes observed in the first 

half of 2024. Linkage processing costs 

would be reduced from approximately 

$27,000 per day to $0 per day, resulting 

in estimated annual linkage processing 

savings of $7,128,000 ($27,000/day × 

264 days). Data processing costs (i.e., 

costs attributable to data ingestion and 

preparation and publication of data 

versions to the relevant regulatory 

interfaces) would be reduced from 

approximately $27,000 per day to 

$9,000 per day, resulting in estimated 

annual data processing savings of 

$4,752,000 ($18,000/day × 264 days). In 

the aggregate, linkage processing and 

data processing savings would total 

$11,880,000, or approximately $12 

million, based on data volumes 

observed in the first half of 2024. If data 

volumes continue to increase as they 

have historically, the associated costs 

avoided would similarly increase. 

Storage Requirements. The Plan 

Processor estimates that approximately 

$8 million in savings would be 

attributable to the reduction in the 

storage footprint for Options Market 

Maker quotes in Listed Options through 

the elimination of versioned quote data 

(i.e., T+2 8 a.m. ET, T+5 8 a.m. ET, 

DIVER and OLA copies). The $8 million 

in savings assumes a reduction of the 

current production storage footprint of 

approximately 37.5 petabytes (PB) per 

month based on data volumes from the 

first half of 2024 to approximately 9 PB 

per month spread across the S3 

Intelligent Tiers (Frequent Access, 

Infrequent Access, and Archive Instant 

Access).24

Query Requirements. As described in 

the SRO Letter, the Plan Processor 

estimates that the continued 

optimization of Options Market Maker 

quotes in Listed Options to make them 

available via DIVER would cost 

approximately $2.8 million per year. 

This estimate consists of (i) $2.2 million 

per year in compute costs for producing 

the DIVER-specific hash partition copy 

of Options Market Maker quotes; 25 and 

(ii) $600,000 per year in storage costs for 

one year’s worth of DIVER-specific 

copies of Options Market Maker 

quotes.26 These amounts are included in 

the processing and storage estimates 

described above. 

2. Storage for Raw Unprocessed Data 

and Interim Operational Copies of CAT 

Data Older Than 15 Days: Estimated 

Annual Savings of $1 Million 

The Proposed Cost Savings 

Amendments would save approximately 

$1 million annually by permitting the 

Plan Processor to move raw 

unprocessed data (i.e., as-submitted 

data) and interim operational data older 

than 15 days to a more cost-effective 

storage tier that is optimized for 

infrequent access. 

The estimated $1 million in reduced 

storage costs are attributable to storage 

pricing for Glacier Deep Archive, 

currently the lowest storage tier 

available on AWS cloud, and are based 

on data volumes observed in the first 

half of 2024.27

CAT LLC reiterates that the affected 

data provides minimal regulatory value 

after the final corrected data version is 

delivered by T+5 at 8 a.m. ET. When a 

regulator queries CAT data, the CAT 

provides results to the user based on the 

latest, most current version of the data. 

As required by the CAT NMS Plan, prior 

to 12:00 p.m. on T+1, raw unprocessed 

data (i.e., as-submitted data) that has 

been ingested by the Plan Processor 

must be available to Participants’ 

regulatory staff and the SEC. Between 

T+1 and T+5, the CAT query tools will 

return the latest iteration of processed 

data available. Any interim data 

versions are ultimately supplanted in all 

CAT query tools by the final version of 

corrected data that is made available at 

T+5 at 8:00 a.m. ET. Accordingly, raw 

unprocessed data and the various 

iterations of interim operational data 

delivered between T+1 and T+5 provide 

minimal regulatory value after T+5, and 

regulators are unlikely to access this 

data after T+5. Currently, regulators may 

access such data ‘‘without manual 

intervention’’ as required by the CAT 

NMS Plan via the use of CAT data 

management APIs, but after four years of 

operation, the Plan Processor has not 

seen any regulatory usage of this data. 

CAT LLC further reiterates that it is 

not proposing to delete this data; rather, 

it is only asking the Commission to 

allow the Plan Processor to move this 

data to a more cost-effective storage tier 

requiring some ‘‘manual intervention’’ 

in order to save $1 million annually. 

Upon request by the Staff to the CAT 

Help Desk, archived data would be 


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28OIP at 58847. As described in the SRO Letter, 

the ‘‘Eliminated Enrichments’’ are ‘‘(i) derived next 

event timestamp; (ii) lifecycle sequence number; 

and (iii) the CAT Lifecycle ID.’’ SRO Letter at 5. See 

also Proposed Cost Savings Amendments at 4; 

Notice at 26985. 

29The CAT Order ID is the lifecycle ID across all 

CAT Reporters whereas the Venue Order ID is the 

lifecycle ID within a single CAT Reporter. Because 

option quote events only exist within a single CAT 

Reporter, the CAT Order ID and Venue Order ID are 

identical for such events. 30OIP at 58847. 31 17 CFR 200.30–3(a)(85). 

restored by the Plan Processor to an 

accessible storage tier, at which point it 

would be available and searchable 

electronically by the Staff in the same 

manner it is today. 

3. Provision of an Interim CAT-Order-ID 

on an ‘‘As Requested’’ Basis: Estimated 

Annual Savings of $2 Million 

As noted above, after discussions with 

the Staff, the proposal to provide an 

interim CAT-Order-ID to the 

Commission on an ‘‘as requested’’ basis 

has been withdrawn. Accordingly, the 

$2 million in annual cost savings 

associated with this proposal have been 

eliminated. The Plan Processor will 

continue to be required to produce an 

interim CAT-Order-ID on a daily basis. 

III. Additional Responses to OIP 

A. Processing, Query, and Storage 

Requirements for Options Market Maker 

Quotes in Listed Options 

Under the Proposed Cost Savings 

Amendments, Options Market Maker 

quotes in Listed Options will no longer 

be subject to enrichment processing. 

The Commission requested, ‘‘in 

addition to the three ‘Eliminated 

[Enrichments]’ discussed in the SRO 

Letter, . . . more information on data 

elements—namely, a list of fields and 

variables for various event types in 

current CAT Data—that would no longer 

be directly available, would only be 

available indirectly (via notifications or 

making of requests to the Plan Processor 

or other entities), or would be available 

on a delay relative to today.’’ 28

As previously described, the 

following data elements will no longer 

be available in CAT under the Proposed 

Cost Savings Amendments: 

• Derived Next Event Timestamp/ 

Derived Next Event Epoch Timestamp 

• CAT Lifecycle Sequence Number 

• CAT Lifecycle ID (i.e., CAT Order 

ID and Venue Order ID) 29

In addition to the elements previously 

noted, the Derived Next Event Type 

Code will no longer be available under 

the proposed amendments. 

In addition, the following processing 

enrichments, which can be 

characterized as linkage metadata, will 

no longer be available: 

• Intra Venue Link Status Code 

• Unlinked Indicator 

• Lifecycle Assembly Date 

• Associated Lifecycles 

As reflected in the proposed 

amendment as revised, upon request of 

the SEC or any Participant, the Plan 

Processor will provide the existing code 

required to derive any eliminated data 

elements from the unprocessed data. 

Finally, the Staff requested 

information regarding how the ‘‘Top 

Indicator’’ data element would be 

affected under the proposed 

amendments. Plan Participant events do 

not represent the top of a lifecycle. 

Accordingly, the ‘‘Top Indicator’’ is not 

an enrichment available on Plan 

Participant events. 

B. Provision of an Interim CAT-Order-ID 

on an ‘‘As Requested’’ Basis 

The Commission requested certain 

additional information regarding the 

proposal to provide an interim CATOrder-ID on an ‘‘as requested’’ basis.30

As noted above, this proposal has been 

withdrawn after discussions with the 

Staff. Therefore, CAT LLC believes it is 

no longer necessary to respond to this 

portion of the OIP. 

IV. Solicitation of Comments 

The Commission seeks comments on 

the proposed additional revisions to the 

Proposed Cost Savings Amendments. 

Interested persons are invited to submit 

written data, views, and arguments 

concerning the foregoing, including 

whether the proposed additional 

revisions to the Proposed Cost Savings 

Amendments are consistent with the 

Exchange Act. Comments may be 

submitted by any of the following 

methods: 

Electronic Comments 

• Use the Commission’s internet 

comment form (https://www.sec.gov/ 

rules/sro.shtml); or 

• Send an email to rule-comments@

sec.gov. Please include File Number 4– 

698 on the subject line. 

Paper Comments 

• Send paper comments in triplicate 

to Secretary, Securities and Exchange 

Commission, 100 F Street NE, 

Washington, DC 20549–1090. 

All submissions should refer to File 

Number 4–698. This file number should 

be included on the subject line if email 

is used. To help the Commission 

process and review your comments 

more efficiently, please use only one 

method. The Commission will post all 

comments on the Commission’s internet 

website (https://www.sec.gov/rules/ 

sro.shtml). Copies of the submission, all 

subsequent amendments, all written 

statements with respect to the Proposed 

Cost Savings Amendments that are filed 

with the Commission, and all written 

communications relating to the 

Proposed Cost Savings Amendments 

between the Commission and any 

person, other than those that may be 

withheld from the public in accordance 

with the provisions of 5 U.S.C. 552, will 

be available for website viewing and 

printing in the Commission’s Public 

Reference Room, 100 F Street NE, 

Washington, DC 20549, on official 

business days between the hours of 

10:00 a.m. and 3:00 p.m. Copies of the 

filing also will be available for 

inspection and copying at the 

Participants’ offices. All comments 

received will be posted without change. 

Persons submitting comments are 

cautioned that we do not redact or edit 

personal identifying information from 

comment submissions. You should 

submit only information that you wish 

to make available publicly. All 

submissions should refer to File 

Number 4–698 and should be submitted 

on or before October 28, 2024. 

For the Commission, by the Division of 

Trading and Markets, pursuant to delegated 

authority.31

Sherry R. Haywood, 

Assistant Secretary. 

Exhibit A 

Cumulative Proposed Revisions to CAT 

NMS Plan 

Additions italicized; deletions 

[bracketed] 

* * * * * 

Article VI 

Functions and Activities of CAT System 

* * * * * 

Section 6.5. Central Repository. 

* * * * * 

(b) Retention of Data. 

(i) Consistent with Appendix D, Data 

Retention Requirements, the Central 

Repository shall retain the information 

collected pursuant to paragraphs (c)(7) and 

(e)(7) of SEC Rule 613 in a convenient and 

usable standard electronic data format that is 

directly available and searchable 

electronically without any manual 

intervention by the Plan Processor for a 

period of not less than six (6) years, subject 

to the exceptions in Section 6.3 of Appendix 

D. Such data when available to the 

Participant regulatory staff and the SEC shall 

be linked. 

(ii) The Plan Processor shall implement 

and comply with the records retention policy 

contemplated by Section 6.1(d)(i) (as such 


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policy is reviewed and updated periodically 

in accordance with Section 6.1(d)(i)). 

* * * * * 

Appendix D 

* * * * * 

1.2 Technical Environments 

The architecture must include 

environments for production, development, 

quality assurance testing, disaster recovery, 

industry-wide coordinated testing, and 

individual on-going CAT Reporter testing. 

The building and introduction of 

environments available to CAT Reporters 

may be phased in to align with the following 

agreed upon implementation milestones: 

• Development environment—the 

development environment must be created to 

build, develop, and maintain enhancements 

and new requirements. This environment 

must be separate from those listed below. 

• Quality assurance environment—a 

quality assurance (QA) environment must be 

created to allow simulation and testing of all 

applications, interfaces, and data integration 

points contained in the CAT System. 

Æ The QA environment shall be able to 

simulate end-to-end production functionality 

and perform with the same operational 

characteristics, including processing speed, 

as the production environment. 

Æ The QA environment shall support 

varied types of changes, such as, but not 

limited to, the following: 

• Application patches; 

• Bug fixes; 

• Operating system upgrades; 

• Introduction of new hardware or 

software components; 

• New functionality; 

• Network changes; 

• Regression testing of existing 

functionality; 

• Stress or load testing (simulation of 

production-level usage); and 

• Recovery and failover. 

Æ A comprehensive test plan for each 

build and subsequent releases must be 

documented. 

• Production environment—fully 

operational environment that supports 

receipt, ingestion, processing and storage of 

CAT Data. Backup/disaster recovery 

components must be included as part of the 

production environment. 

• Industry test environment— 

Æ The Plan Processor must provide an 

environment supporting industry testing (test 

environment) that is functionally equivalent 

to the production environment, including: 

• End-to-end functionality (e.g., data 

validation, processing, linkage, error 

identification, correction and reporting 

mechanism) from ingestion to output, sized 

to meet the standards of the production SLA; 

• Performance metrics that mirror the 

production environment; and 

• Management with the same information 

security policies applicable to the production 

environment. 

Æ The industry test environment must also 

contain functionality to support industry 

testing, including: 

• Minimum availability of 24x6; 

• Replica of production data when needed 

for testing; 

• Data storage sized to meet varying needs, 

dependent upon scope and test scenarios; 

and 

• Support of two versions of code (current 

and pending). 

Æ The industry test environment must 

support the following types of industry 

testing: 

• Technical upgrades made by the Plan 

Processor; 

• CAT code releases that impact CAT 

Reporters; 

• Changes to industry data feeds (e.g., SIP, 

OPRA, etc.); 

• Industry-wide disaster recovery testing; 

• Individual CAT Reporter and Data 

Submitter testing of their upgrades against 

CAT interfaces and functionality; and 

• Multiple, simultaneous CAT Reporter 

testing. 

Æ The industry test environment must be 

a discrete environment separate from the 

production environment. 

Æ The Plan Processor must provide the 

linkage processing of data submitted during 

coordinated, scheduled, industry-wide 

testing. Results of the linkage processes must 

be communicated back to Participants as well 

as to the Operating Committee. 

Æ Data from industry testing must be saved 

for three months. Notwithstanding any other 

provision of the CAT NMS Plan, this 

Appendix D, or Exchange Act Rule 17a–1, 

such test data (whether related to the CAT 

order and transaction system or the customer 

account and information system) may be 

deleted by the Plan Processor after three 

months. Operational metrics associated with 

industry testing (including but not limited to 

testing results, firms who participated, and 

amount of data reported and linked) must be 

stored for the same duration as the CAT 

production data. 

Æ The Plan Processor must provide 

support for industry testing, including testing 

procedures, coordination of industry testing, 

publish notifications, and provide help desk 

support during industry testing. 

Æ The Participants and the SEC must have 

access to industry test data. 

* * * * * 

1.4 Data Retention Requirements 

The Plan Processor must develop a formal 

record retention policy and program for the 

CAT, to be approved by the Operating 

Committee, which will, at a minimum: 

• Contain requirements associated with 

data retention, maintenance, destruction, and 

holds; 

• Comply with applicable SEC recordkeeping requirements; 

• Have a record hold program where 

specific CAT Data can be archived offline for 

as long as necessary; 

• Store and retain both raw data submitted 

by CAT Reporters and processed data; and 

• Make data directly available and 

searchable electronically without manual 

intervention for at least six years, subject to 

the exceptions in Section 6.3 of Appendix D. 

* * * * * 

3. Reporting and Linkage Requirements 

All CAT Data reported to the Central 

Repository must be processed and assembled 

to create the complete lifecycle of each 

Reportable Event. Reportable Events must 

contain data elements sufficient to ensure the 

same regulatory coverage currently provided 

by existing regulatory reporting systems that 

have been identified as candidates for 

retirement. 

Additionally, the Central Repository must 

be able to: 

• Assign a unique CAT-Reporter-ID to all 

reports submitted to the system based on subidentifiers, (e.g., MPIDs, ETPID, trading 

mnemonic) currently used by CAT Reporters 

in their order handling and trading processes. 

• Handle duplicate sub-identifiers used by 

members of different Participants to be 

properly associated with each Participant. 

• Generate and associate one or more 

Customer-IDs with all Reportable Events 

representing new orders received from a 

Customer(s) of a CAT Reporter. The 

Customer-ID(s) will be generated from a Firm 

Designated ID provided by the CAT Reporter 

for each such event, which will be included 

on all new order events. 

• Accept time stamps on order events 

handled electronically to the finest level of 

granularity captured by CAT Reporters. 

Additionally, the CAT must be able to 

expand the time stamp field to accept time 

stamps to an even finer granularity as trading 

systems expand to capture time stamps in 

ever finer granularity. The Plan Processor 

must normalize all processed date/time CAT 

Data into a standard time zone/format. 

In addition, the data required from CAT 

Reporters will include all events and data 

elements required by the Plan Processor in 

the Technical Specifications to build the: 

• Life cycle of an order for defined events 

within a CAT Reporter; 

• Life cycle of an order for defined events 

intra-CAT Reporter; and 

• State of all orders across all CAT 

Reporters at any point in time. 

The Plan Processor must use the ‘‘daisy 

chain approach’’ to link and create the order 

lifecycle. In the daisy chain approach, a 

series of unique order identifiers, assigned to 

all order events handled by CAT Reporters 

are linked together by the Central Repository 

and assigned a single CAT-generated CATOrder-ID that is associated with each 

individual order event and used to create the 

complete lifecycle of an order. 

By using the daisy chain approach the Plan 

Processor must be able to link all related 

order events from all CAT Reporters involved 

in the lifecycle of an order. At a minimum, 

the Central Repository must be able to create 

the lifecycle between: 

• All order events handled within an 

individual CAT Reporter, including orders 

routed to internal desks or departments with 

different functions (e.g., an internal ATS); 

• Customer orders to ‘‘representative’’ 

orders created in firm accounts for the 

purpose of facilitating a customer order (e.g., 

linking a customer order handled on a 

riskless principal basis to the street-side 

proprietary order); 

• Orders routed between broker-dealers; 

• Orders routed from broker-dealers to 

exchanges; 

• Orders sent from an exchange to its 

routing broker-dealer; 


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• Executed orders and trade reports; 

• Various legs of option/equity complex 

orders; and 

• Order events for all equity and option 

order handling scenarios that are currently or 

may potentially be used by CAT Reporters, 

including: 

Æ Agency route to another broker-dealer or 

exchange; 

Æ Riskless principal route to another 

broker-dealer or exchange capturing within 

the lifecycle both the customer leg and street 

side principal leg; 

Æ Orders routed from one exchange 

through a routing broker-dealer to a second 

exchange; 

Æ Orders worked through an average price 

account capturing both the individual street 

side execution(s) and the average price fill to 

the Customer; 

Æ Orders aggregated with other orders for 

further routing and execution capturing both 

the street side executions for the aggregated 

order and the fills to each customer order; 

Æ Complex orders involving one or more 

options legs and an equity leg, with a linkage 

between the option and equity legs; 

Æ Complex orders containing more legs 

than an exchange’s order management system 

can accept, causing the original order to be 

broken into multiple orders; 

Æ Orders negotiated over the telephone or 

via a negotiation system; 

Æ Orders routed on an agency basis to a 

foreign exchange; 

Æ Execution of customer order via 

allocation of shares from a pre-existing 

principal order; 

Æ Market maker quotes; and 

Æ Complex orders involving two or more 

options legs. 

Additionally, the Central Repository must 

be able to: 

• Link each order lifecycle back to the 

originating Customer; 

• Integrate and appropriately link reports 

representing repairs of original submissions 

that are rejected by the CAT due to a failure 

to meet a particular data validation; 

• Integrate into the CAT and appropriately 

link reports representing records that are 

corrected by a CAT Reporter for the purposes 

of correcting data errors not identified in the 

data validation process; 

• Assign a single CAT-Order-ID to all 

events contained within the lifecycle of an 

order so that regulators can readily identify 

all events contained therein; and 

• Process and link Manual Order Events 

with the remainder of the associated order 

lifecycle. 

As described in Section 3.4 of Appendix D, 

Options Market Maker quotes in Listed 

Options will be subject to ingestion only and 

will not be subject to any linkage 

requirements. 

* * * * * 

3.4 Requirements for Options Market Maker 

Quotes in Listed Options 

The provisions of this section shall govern 

the processing and storage of Options Market 

Maker quotes in Listed Options and shall 

override any conflicting provisions in the 

CAT NMS Plan, this Appendix D, or 

Exchange Act Rule 17a–1. 

Options Market Maker quotes in Listed 

Options must be reported to the Central 

Repository as provided under Section 

6.4(d)(iii) of the CAT NMS Plan. This data 

will undergo ingestion validation only and 

such unlinked data will be made available to 

regulators by T+1 at 12:00 p.m. Eastern Time. 

Options Market Maker quotes in Listed 

Options will not be subject to any 

requirement to link and create an order 

lifecycle, and will not undergo any linkage 

validation, linkage feedback, or lifecycle 

enrichment processing, but will undergo 

ingestion validation. Options Market Maker 

quotes in Listed Options will be accessible 

through BDSQL and Direct Read interfaces 

only and will not be accessible through the 

online targeted query tool. 

Upon request of the SEC or any 

Participant, the Plan Processor will provide 

the business and technical requirements 

needed to re-create the eliminated 

enrichments, as well as the code (which is 

unique to the Plan Processor’s linkage 

implementation) existing as of the effective 

date of this provision used to derive the 

eliminated enrichments. The Plan Processor 

will not maintain the business and technical 

requirements and the code following the 

effective date of this provision, but it will 

retain a copy so that they may be provided 

to any regulators that might request them in 

the future. 

* * * * * 

6.1 Data Processing 

CAT order events must be processed 

within established timeframes to ensure data 

can be made available to Participants’ 

regulatory staff and the SEC in a timely 

manner. The processing timelines start on the 

day the order event is received by the Central 

Repository for processing. 

Most events must be reported to the CAT 

by 8:00 a.m. Eastern Time the Trading Day 

after the order event occurred (referred to as 

transaction date). The processing timeframes 

below are presented in this context. All 

events submitted after T+1 (either reported 

late or submitted later because not all of the 

information was available) must be processed 

within these timeframes based on the date 

they were received. 

The Participants require the following 

timeframes (Figure A) for the identification, 

communication and correction of errors from 

the time an order event is received by the 

processor: 

• Noon Eastern Time T+1 (transaction date 

+ one day)—Initial data validation, lifecycle 

linkages and communication of errors to CAT 

Reporters; 

• 8:00 a.m. Eastern Time T+3 (transaction 

date + three days)—Resubmission of 

corrected data; and 

• 8:00 a.m. Eastern Time T+5 (transaction 

date + five days)—Corrected data available to 

Participant regulatory staff and the SEC. 

Late submissions or re-submissions (after 

8:00 a.m.) may be considered to be processed 

that day if it falls within a given time period 

after the cutoff. This threshold will be 

determined by the Plan Processor and 

approved by the Operating Committee. In the 

event that a significant portion of the data 

has not been received as monitored by the 

Plan Processor, the Plan Processor may 

decide to halt processing pending submission 

of that data. 


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Figure A: CAT Central Repository Data Processing Timelines 

T+1 

12:0IAIET 

T+1 

.·• lmial Validation,. Lin! •• ~Li~. 

eommu~or 

Errors 

8:00.AYET 

T+l 

T+4 
Federal Register / Vol. 89, No. 194 / Monday, October 7, 2024 / Notices 81127 

29Specific performance requirements will be 

included in the SLA. 

For the avoidance of doubt, processing and 

storage of Options Market Maker quotes in 

Listed Options shall be governed by Section 

3.4 of Appendix D. 

* * * * * 

6.3 Exceptions to Data Availability 

Requirements 

Notwithstanding any other provision of the 

CAT NMS Plan, this Appendix D, or 

Exchange Act Rule 17a–1, the following types 

of data may be retained in an archive storage 

tier. Archived data is not directly available 

and searchable electronically without 

manual intervention and will not be subject 

to any query tool performance requirements 

until it is restored to an accessible storage 

tier. The Plan Processor will restore archived 

data to an accessible storage tier upon 

request to the CAT Help Desk by an 

authorized regulatory user from the 

Participants or a senior officer from the SEC. 

• Raw Unprocessed Data older than 15 

days. ‘‘Raw Unprocessed Data’’ means data 

that has been ingested by the Plan Processor 

and made available to regulators prior to 

12:00 p.m. Eastern Time on T+1. 

• Interim Operational Data older than 15 

days. ‘‘Interim Operational Data’’ means all 

processed, validated and unlinked data 

made available to regulators by T+1 at 12:00 

p.m. ET and all iterations of processed data 

made available to regulators between T+1 

and T+5, but excludes the final version of 

corrected data that is made available at T+5 

at 8:00 a.m. ET. For the avoidance of doubt, 

‘‘Interim Operational Data’’ does not include 

processed data relating to Options Market 

Maker quotes in Listed Options made 

available to regulators by T+1 at 12:00 p.m. 

ET. 

• All submission and feedback files older 

than 15 days. 

* * * * * 

8.1 Regulator Access 

The Plan Processor must provide 

Participants’ regulatory staff and the SEC 

with access to all CAT Data for regulatory 

purposes only. Participants’ regulatory staff 

and the SEC will access CAT Data to perform 

functions, including economic analyses, 

market structure analyses, market 

surveillance, investigations, and 

examinations. 

The CAT must be able to support, at a 

minimum, 3,000 regulatory users within the 

system. It is estimated that approximately 

20% of all users will use the system on a 

daily or weekly basis while approximately 

10% of all users will require advanced 

regulator-user access, as described below. 

Furthermore, it is estimated that there may be 

approximately 600 concurrent users 

accessing the CAT at any given point in time. 

These users must be able to access and use 

the system without an unacceptable decline 

in system performance.29

As stated in Appendix D, Data Security, 

the Plan Processor must be able to support 

an arbitrary number of user roles. Defined 

roles must include, at a minimum: 

• Basic regulator users—Individuals with 

approved access who plan to use the Central 

Repository to run basic queries (e.g., pulling 

all trades in a single stock by a specific 

party). 

• Advanced regulator users—Individuals 

with approved access who plan to use the 

Central Repository to construct and run their 

own complex queries. 

Regulators will have access to processed 

CAT Data through two different methods, an 

online-targeted query tool and user-defined 

direct queries and bulk extracts. 

As described in Section 3.4 of Appendix D, 

Options Market Maker quotes in Listed 

Options will be accessible through BDSQL 

and Direct Read interfaces only and will not 

be accessible through the online targeted 

query tool. 

Exhibit B 

Proposed Additional Revisions to Changes in 

Proposed Cost Savings Amendment 

Additions italicized; deletions [bracketed] 

* * * * * 

Appendix D 

* * * * * 

3. Reporting and Linkage Requirements 

* * * * * 

As described in Section 3.4 of Appendix D, 

Options Market Maker [Quotes]quotes in 

Listed Options [and related Reportable 

Events] will be subject to ingestion only and 

will not be subject to any linkage 

requirements. 

* * * * * 

3.4 Requirements for Options Market Maker 

Quotes in Listed Options 

The provisions of this section shall govern 

the processing and storage of Options Market 

Maker [Quotes]quotes in Listed Options [and 

related Reportable Events] and shall override 

any conflicting provisions in the CAT NMS 

Plan, this Appendix D, or Exchange Act Rule 

17a–1. 

Options Market Maker [Quotes]quotes in 

Listed Options must be reported to the 

Central Repository as provided under Section 

6.4(d)(iii) of the CAT NMS Plan. This data 

will undergo ingestion validation only and 

such unlinked data will be made available to 

regulators by T+1 at 12:00 p.m. Eastern Time. 

Options Market Maker [Quotes]quotes in 

Listed Options will not be subject to any 

requirement to link and create an order 

lifecycle, and will not undergo any linkage 

validation, linkage feedback, [linkage,] or 

lifecycle enrichment processing, but will 

undergo ingestion validation. Options Market 

Maker [Quotes]quotes in Listed Options will 

be accessible through BDSQL and Direct 

Read interfaces only and will not be 

accessible through the online targeted query 

tool. 

Upon request of the SEC or any 

Participant, the Plan Processor will provide 

the business and technical requirements 

needed to re-create the eliminated 

enrichments, as well as the code (which is 

unique to the Plan Processor’s linkage 

implementation) existing as of the effective 

date of this provision used to derive the 

eliminated enrichments. The Plan Processor 

will not maintain the business and technical 

requirements and the code following the 

effective date of this provision, but it will 

retain a copy so that they may be provided 

to any regulators that might request them in 

the future. 

* * * * * 

6.1 Data Processing 

CAT order events must be processed 

within established timeframes to ensure data 

can be made available to Participants’ 

regulatory staff and the SEC in a timely 

manner. The processing timelines start on the 

day the order event is received by the Central 

Repository for processing. Most events must 

be reported to the CAT by 8:00 a.m. Eastern 

Time the Trading Day after the order event 

occurred (referred to as transaction date). The 

processing timeframes below are presented in 

this context. All events submitted after T+1 

(either reported late or submitted later 

because not all of the information was 

available) must be processed within these 

timeframes based on the date they were 

received. 

The Participants require the following 

timeframes (Figure A) for the identification, 

communication and correction of errors from 

the time an order event is received by the 

processor: 

• Noon Eastern Time T+1 (transaction date 

+ one day)—Initial data validation, lifecycle 

linkages and communication of errors to CAT 

Reporters; 

• 8:00 a.m. Eastern Time T+3 (transaction 

date + three days)—Resubmission of 

corrected data; and 

• 8:00 a.m. Eastern Time T+5 (transaction 

date + five days)—Corrected data available to 

Participant regulatory staff and the SEC. 

Late submissions or re-submissions (after 

8:00 a.m.) may be considered to be processed 

that day if it falls within a given time period 

after the cutoff. This threshold will be 

determined by the Plan Processor and 

approved by the Operating Committee. In the 

event that a significant portion of the data 

has not been received as monitored by the 

Plan Processor, the Plan Processor may 

decide to halt processing pending submission 

of that data. 


lotter on DSK11XQN23PROD with NOTICES1
81128 Federal Register / Vol. 89, No. 194 / Monday, October 7, 2024 / Notices 

[Where there is an immediate regulatory 

need (for example, in the case of a major 

market event), upon request of a senior 

officer of the Division of Trading and 

Markets, the Division of Enforcement, or the 

Division of Examinations to CAT LLC, the 

Plan Processor shall be directed to create an 

interim CAT-Order-ID and make it available 

to regulators by T+1 at 9 p.m. ET if the 

request is received prior to T+1 at 8 a.m. ET, 

or generally within 14 hours of receiving the 

request if such request was received after T+1 

at 8 a.m. ET.] 

For the avoidance of doubt, processing and 

storage of Options Market Maker 

[Quotes]quotes in Listed Options [and related 

Reportable Events] shall be governed by 

Section 3.4 of Appendix D. 

* * * * * 

6.3 Exceptions to Data Availability 

Requirements 

Notwithstanding any other provision of the 

CAT NMS Plan, this Appendix D, or 

Exchange Act Rule 17a–1, the following 

types of data may be retained in an archive 

storage tier[, in which case they will be made 

available upon request by Participant 

regulatory staff or the SEC to the CAT Help 

Desk]. Archived data is not directly available 

and searchable electronically without manual 

intervention and will not be subject to any 

query tool performance requirements until it 

is restored to an accessible storage tier. The 

Plan Processor will restore archived data to 

an accessible storage tier upon request to the 

CAT Help Desk by an authorized regulatory 

user from the Participants or a senior officer 

from the SEC. 

• [All raw unprocessed data (i.e., as 

submitted data) and interim operational data 

older than 15 days. Interim operational data 

includes all processed, validated and 

unlinked data made available to regulators by 

T+1 at 12:00 p.m. ET, and all iterations of 

processed data made available to regulators 

between T+1 and T+5, but excludes the final 

version of corrected data that is made 

available at T+5 at 8:00 a.m. ET.]Raw 

Unprocessed Data older than 15 days. ‘‘Raw 

Unprocessed Data’’ means data that has been 

ingested by the Plan Processor and made 

available to regulators prior to 12:00 p.m. 

Eastern Time on T+1. 

• Interim Operational Data older than 15 

days. ‘‘Interim Operational Data’’ means all 

processed, validated and unlinked data 

made available to regulators by T+1 at 12:00 

p.m. ET and all iterations of processed data 

made available to regulators between T+1 

and T+5, but excludes the final version of 

corrected data that is made available at T+5 

at 8:00 a.m. ET. For the avoidance of doubt, 

‘‘Interim Operational Data’’ does not include 

processed data relating to Options Market 

Maker quotes in Listed Options made 

available to regulators by T+1 at 12:00 p.m. 

ET. 

• All submission and feedback files older 

than 15 days. 

* * * * * 

8.1 Regulator Access 

* * * * * 

As described in Section 3.4 of Appendix D, 

Options Market Maker [Quotes ]quotes in 

Listed Options [and related Reportable 

Events] will be accessible through BDSQL 

and Direct Read interfaces only and will not 

be accessible through the online targeted 

query tool. 

[FR Doc. 2024–23063 Filed 10–4–24; 8:45 am] 

BILLING CODE 8011–01–P 

SECURITIES AND EXCHANGE 

COMMISSION 

Sunshine Act Meetings 

TIME AND DATE: 2:00 p.m. on Thursday, 

October 10, 2024. 

PLACE: The meeting will be held via 

remote means and/or at the 

Commission’s headquarters, 100 F 

Street NE, Washington, DC 20549. 

STATUS: This meeting will be closed to 

the public. 

MATTERS TO BE CONSIDERED: 

Commissioners, Counsel to the 

Commissioners, the Secretary to the 

Commission, and recording secretaries 

will attend the closed meeting. Certain 

staff members who have an interest in 

the matters also may be present. 

In the event that the time, date, or 

location of this meeting changes, an 

announcement of the change, along with 

the new time, date, and/or place of the 

meeting will be posted on the 

Commission’s website at https://

www.sec.gov. 

The General Counsel of the 

Commission, or her designee, has 

certified that, in her opinion, one or 

more of the exemptions set forth in 5 

U.S.C. 552b(c)(3), (5), (6), (7), (8), 9(B) 

and (10) and 17 CFR 200.402(a)(3), 

(a)(5), (a)(6), (a)(7), (a)(8), (a)(9)(ii) and 

(a)(10), permit consideration of the 

scheduled matters at the closed meeting. 

The subject matter of the closed 

meeting will consist of the following 

topics: 

Institution and settlement of injunctive 

actions; 

Institution and settlement of 

administrative proceedings; 

Resolution of litigation claims; and 

Other matters relating to examinations 

and enforcement proceedings. 

At times, changes in Commission 

priorities require alterations in the 

scheduling of meeting agenda items that 

may consist of adjudicatory, 

examination, litigation, or regulatory 

matters. 

CONTACT PERSON FOR MORE INFORMATION: 

For further information, please contact 

Vanessa A. Countryman from the Office 

of the Secretary at (202) 551–5400. 

Authority: 5 U.S.C. 552b. 

Dated: October 3, 2024. 

Vanessa A. Countryman, 

Secretary. 

[FR Doc. 2024–23263 Filed 10–3–24; 4:15 pm] 

BILLING CODE 8011–01–P 


lotter on DSK11XQN23PROD with NOTICES1EN07OC24.012</GPH>

Figure A: CAT Central Repository Data Processing Timelines 

T+4 

R:l!pmi:essingof 

Enm 

c-tions 

[{changes to second box in chart: 12:00 PM ET T+l Initial Validation, Life Cycle Linkage, 

Communication of Errors}]