Consolidated audit proposed funding model

The comment period on a revised funding model (“Proposed Funding Model”) for the consolidated audit trail (“CAT”) recently closed. The Original Funding Model was bifurcated, with the costs associated with building and operating the CAT borne by Industry Members (i.e., broker dealers) and Participants and industry members that are execution venues (i.e., exchanges and ATSs) based on, among other things, message traffic and market share. The Proposed Funding Model keeps some aspects of the Original, but also makes several changes to how revenue and expenses should be split. Several industry groups submitted comments seeking more clarity on how costs of running the CAT should be allocated or expressed concerns with the analysis underlying the proposal.