On July 18, MFA submitted a letter to the SEC in response to its Notice on the Consolidated Audit Trail (CAT) Plan. In the letter, MFA supports the SEC and the NMS Plan Participants’ (SROs’) goal of modernizing the regulatory data infrastructure upon which regulators rely for overseeing the markets. In order to ensure that the Consolidated Audit Trail, as a vital resource, remains a positive for all involved and does not become a threat to market stability or national security, MFA urges that the SEC and the NMS Plan Participants must take robust action to ensure that CAT data information is given the protection it requires and that the CAT System is not susceptible to cyberattack or other forms of information misappropriation. In MFA’s letter, MFA provided a number of comments and recommendations for the Commission to consider for enhancing the CAT NMS Plan. MFA believes that the NMS CAT Plan should be designed in a manner that: (1) does not create a new national security vulnerability; (2) mitigates the risk of data security breaches; and (3) allows for the elimination of duplicative filings currently provided by market participants.
