PTG responds to SEC CAT Concept Release
Jun 22, 2026
In a letter filed today with the Securities and Exchange Commission (SEC), PTG urges the Commission to take direct control over Consolidated Audit Trail (CAT) funding and governance. The letter recommends the SEC fund CAT through the existing Section 31 fee process by incorporating CAT costs into the Commission’s Congressionally approved budget. PTG argues this would add legislative oversight, fiscal discipline, and accountability while still allowing the industry to cover costs through the existing fee mechanism.
PTG also recommends replacing the current CAT NMS Plan structure with a direct CAT Commission rule that includes recordkeeping and reporting requirements. PTG argues the current governance model creates conflicts of interest, misaligned incentives, and inadequate cost control. A Commission-led model would streamline governance, subject future CAT scope changes to economic analysis and public comment and better align CAT with its regulatory purpose.
To support this transition, PTG recommends creating a Commission-led CAT advisory committee, conducting a cost-benefit review of CAT requirements, analyzing regulator usage costs and SRO usage fees, performing an independent technology review, applying CAT rules consistently to evolving markets, strengthening data security, and retiring duplicative systems such as electronic blue sheets and Large Trader Reporting.
The letter concludes that bringing CAT funding and governance under the SEC would improve transparency, fiscal responsibility, oversight, and long-term cost discipline.