<p><span>The proposed </span><a rel="nofollow noopener" target="_blank" href="https://www.sec.gov/rules/sro/nms/2021/34-91487.pdf">limitation of liability provisions</a><span> for the Consolidated Audit Trail (CAT) discourages CAT Participants (i.e. FINRA and the Exchange Groups) from advancing the security protection and design of CAT and CAT data. Although the immunity status of FINRA and Stock Exchanges as Self-Regulatory Organizations (SROs) may be broad, including affirmative acts and omissions and failures to act. SROs, however, do not enjoy complete immunity from suits. According to </span><a rel="nofollow noopener" target="_blank" href="https://caselaw.findlaw.com/us-11th-circuit/1122372.html">Weissman</a><span> and </span><a rel="nofollow noopener" target="_blank" href="https://caselaw.findlaw.com/us-9th-circuit/1274659.html">Sparta Surgical Corp.’s court cases against National Association of Securities Dealers</a><span>, FINRA and presumably all SROs remain subject to liability should claim(s) arises as a result of private business or commercial conduct. </span></p>