Securities and Exchange Commission v. Conditional Exemptive Order, et al.

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FACT SHEET
Reducing the
Operating Costs of
the Consolidated
Audit Trail

U.S. SECURITIES AND EXCHANGE COMMISSION  PAGE 1 OF 3

Why This Matters
The conditional exemptive order allows the self-regulatory organizations that are participants
in the CAT NMS Plan (Participants) to expeditiously and meaningfully reduce CAT operating
costs while retaining the CAT’s core regulatory functionality.

Requirement to Create Lifecycle Linkages by T+1 at Noon ET
Pursuant  to  previous  exemptive  relief  issued  by  the  Commission  in  November  2023,  the
Participants are currently required to provide interim lifecycle linkages by T+1 at 9 p.m. ET
and  final  lifecycle  linkages  by  T+5  at  8  a.m.  ET. In  December  2024,  the  Commission
subsequently approved an amendment to the CAT NMS Plan that removed the requirement
to link and create order lifecycles for Options Market Maker quotes in Listed Options OMM
(OMM  Quotes).  The  exemptive  relief  granted  Sept.  30,  2025,  enables  the  Participants  to
further relax requirements related to the provision of lifecycle linkages.
Specifically, the exemptive relief would allow the CAT NMS Plan processor (Plan Processor)
to provide only final lifecycle linkages for all order events by T+5 at 8 a.m. ET, except that
no  lifecycle  linkages  will  be  required  for  options  market  maker  quotes  in  listed  options
consistent with the December 2024 plan amendments for OMM quotes.  As a condition to
this relief, upon requests made by authorized regulatory users from the Participants or the
Commission, the Plan Processor must create interim CAT Order IDs for a specified trade
date or dates and thereby provide linked lifecycles to regulators before T+5 at 8 a.m. ET.

On Sept. 30, 2025, the Securities and Exchange Commission issued conditional exemptive relief
from certain requirements of the National Market System Plan governing the Consolidated Audit
Trail  (CAT)  (the  “CAT  NMS  Plan”),  Rule  613  of  Regulation  NMS,  and  Rule  17a-1  under  the
Securities Exchange Act of 1934.
This relief addresses four areas related to CAT:
●    Lifecycle linkages
●    Re-processing of late records
●    Providing an online targeted query tool (OTQT)
●    Data storage and retention

FACT SHEET | Reducing the Operating Costs of the Consolidated Audit Trail
U.S. SECURITIES AND EXCHANGE COMMISSION  Page 2 of 3

Requirements for Re-Processing of Late Records
Pursuant  to  previous  exemptive  relief  issued  by  the  Commission  in  November  2023,  the
Participants currently perform certain re-processing on data that is received late, including
re-processing that assembles all late-reported CAT data into complete order event lifecycles
to present such data to regulatory users in a manner substantially similar to how such data
would  have  been  presented  if  it  had  been  reported  on  time  (Full  Replay  process).  The
conditional  exemptive  relief  issued  on Sept.  30,  2025,  enables the  Participants  to  cease
performing the Full Replay process altogether. It also reduces the frequency and scope of
other  weekly  re-processing  for  late  records  known  as  the  Enhanced  Late  to  the  Lifecycle
process, subject to which late records are currently associated with all relevant lifecycles as
part of normal re-processing, such that order event lifecycles may be associated with more
than one CAT Order ID, among other things.
Specifically, pursuant to the conditions of this exemptive relief, the Participants must ensure
that  the  Plan  Processor  maintains  the  Enhanced  Late  to  the  Lifecycle  process  for  late
records (i.e., post T+5 data) from trade dates within the prior three years, including lifecycle
mapping  which  indicates  all  lifecycle  associations  made  during  the  Enhanced  Late  to  the
Lifecycle process. The Enhanced Late to the Lifecycle process must be run quarterly. For
data  outside  of  this  three-year  window,  no  re-processing is  required.  Upon  requests  by
authorized  regulatory  users  from  the  Participants  or  the  Commission,  the  Plan  Processor
must run the Full Replay process on specified data, such that late records received through
Friday of the prior week are available for regulatory users on the following business day at 8
a.m. ET, absent extraordinary circumstances. Finally, the Plan Processor must continue to
notify regulatory users how re-processing will be completed for late records.

Requirement to Provide an OTQT
The  conditional  exemptive  order  grants  relief  to  the  Plan  Processor  from  providing
Participants  and  the  SEC  with  access  to  CAT  Data  through  certain  OTQT  functionality.
However, the Plan Processor must maintain currently-existing controls, monitoring, logging,
and reporting for the remaining query tools – user-defined direct queries and bulk extract, as
well as for certain MIRS tools that are provided as part of the OTQT functionality. In addition,
OTQT  functionality  may  not  be  eliminated  until  two  months  after  the  publication  of  the
conditional exemptive order in the Federal Register.

Requirements Related to Data Storage and Retention
Pursuant to this conditional exemptive relief, the Participants will be allowed to:
• Delete all CAT data older than five years, rather than six years as provided by the CAT
NMS Plan;
• Move CAT data older than three years to a more cost-effective storage tier, which will
not  be  immediately  accessible  but  will  be  made  available  to  regulatory  users  when
requested;

FACT SHEET | Reducing the Operating Costs of the Consolidated Audit Trail
U.S. SECURITIES AND EXCHANGE COMMISSION  Page 3 of 3
• Delete all options market quotes in listed options data after one year; and
• Delete all interim operational data older than 15 days.

What’s Next
The exemptive relief granted by the Commission is immediately effective.

FACT SHEET 
Reducing the 
Operating Costs of 
the Consolidated 
Audit Trail  

 

U.S. SECURITIES AND EXCHANGE COMMISSION  PAGE 1 OF 3 

 

 
Why This Matters 
The conditional exemptive order allows the self-regulatory organizations that are participants 
in the CAT NMS Plan (Participants) to expeditiously and meaningfully reduce CAT operating 
costs while retaining the CAT’s core regulatory functionality. 

 

Requirement to Create Lifecycle Linkages by T+1 at Noon ET 
Pursuant to previous exemptive relief issued by the Commission in November 2023, the 
Participants are currently required to provide interim lifecycle linkages by T+1 at 9 p.m. ET 
and final lifecycle linkages by T+5 at 8 a.m. ET. In December 2024, the Commission 
subsequently approved an amendment to the CAT NMS Plan that removed the requirement 
to link and create order lifecycles for Options Market Maker quotes in Listed Options OMM 
(OMM Quotes). The exemptive relief granted Sept. 30, 2025, enables the Participants to 
further relax requirements related to the provision of lifecycle linkages.  

Specifically, the exemptive relief would allow the CAT NMS Plan processor (Plan Processor) 
to provide only final lifecycle linkages for all order events by T+5 at 8 a.m. ET, except that 
no lifecycle linkages will be required for options market maker quotes in listed options 
consistent with the December 2024 plan amendments for OMM quotes.  As a condition to 
this relief, upon requests made by authorized regulatory users from the Participants or the 
Commission, the Plan Processor must create interim CAT Order IDs for a specified trade 
date or dates and thereby provide linked lifecycles to regulators before T+5 at 8 a.m. ET.  

 
On Sept. 30, 2025, the Securities and Exchange Commission issued conditional exemptive relief 
from certain requirements of the National Market System Plan governing the Consolidated Audit 
Trail (CAT) (the “CAT NMS Plan”), Rule 613 of Regulation NMS, and Rule 17a-1 under the 
Securities Exchange Act of 1934.   
This relief addresses four areas related to CAT:  

● Lifecycle linkages 
● Re-processing of late records 
● Providing an online targeted query tool (OTQT) 
● Data storage and retention 

 



FACT SHEET | Reducing the Operating Costs of the Consolidated Audit Trail 

U.S. SECURITIES AND EXCHANGE COMMISSION  Page 2 of 3 

 
 

Requirements for Re-Processing of Late Records 
Pursuant to previous exemptive relief issued by the Commission in November 2023, the 
Participants currently perform certain re-processing on data that is received late, including 
re-processing that assembles all late-reported CAT data into complete order event lifecycles 
to present such data to regulatory users in a manner substantially similar to how such data 
would have been presented if it had been reported on time (Full Replay process). The 
conditional exemptive relief issued on Sept. 30, 2025, enables the Participants to cease 
performing the Full Replay process altogether. It also reduces the frequency and scope of 
other weekly re-processing for late records known as the Enhanced Late to the Lifecycle 
process, subject to which late records are currently associated with all relevant lifecycles as 
part of normal re-processing, such that order event lifecycles may be associated with more 
than one CAT Order ID, among other things.   

Specifically, pursuant to the conditions of this exemptive relief, the Participants must ensure 
that the Plan Processor maintains the Enhanced Late to the Lifecycle process for late 
records (i.e., post T+5 data) from trade dates within the prior three years, including lifecycle 
mapping which indicates all lifecycle associations made during the Enhanced Late to the 
Lifecycle process. The Enhanced Late to the Lifecycle process must be run quarterly. For 
data outside of this three-year window, no re-processing is required. Upon requests by 
authorized regulatory users from the Participants or the Commission, the Plan Processor 
must run the Full Replay process on specified data, such that late records received through 
Friday of the prior week are available for regulatory users on the following business day at 8 
a.m. ET, absent extraordinary circumstances. Finally, the Plan Processor must continue to 
notify regulatory users how re-processing will be completed for late records. 

 
 

Requirement to Provide an OTQT 
The conditional exemptive order grants relief to the Plan Processor from providing 
Participants and the SEC with access to CAT Data through certain OTQT functionality. 
However, the Plan Processor must maintain currently-existing controls, monitoring, logging, 
and reporting for the remaining query tools – user-defined direct queries and bulk extract, as 
well as for certain MIRS tools that are provided as part of the OTQT functionality. In addition, 
OTQT functionality may not be eliminated until two months after the publication of the 
conditional exemptive order in the Federal Register. 

 
 

Requirements Related to Data Storage and Retention 
Pursuant to this conditional exemptive relief, the Participants will be allowed to: 

• Delete all CAT data older than five years, rather than six years as provided by the CAT 
NMS Plan; 

• Move CAT data older than three years to a more cost-effective storage tier, which will 
not be immediately accessible but will be made available to regulatory users when 
requested; 



FACT SHEET | Reducing the Operating Costs of the Consolidated Audit Trail 

U.S. SECURITIES AND EXCHANGE COMMISSION  Page 3 of 3 

• Delete all options market quotes in listed options data after one year; and 

• Delete all interim operational data older than 15 days. 

 
 

What’s Next 
The exemptive relief granted by the Commission is immediately effective. 

 


	Why This Matters
	Requirements for Re-Processing of Late Records
	Requirement to Provide an OTQT
	Requirements Related to Data Storage and Retention
	What’s Next