<p><span>The US Court of Appeals </span><a href="https://www.cadc.uscourts.gov/internet/opinions.nsf/265FAD4E1FDE293F85258876004F2CF9/$file/21-1167-1953361.pdf">struck down the SEC’s CT-Plan</a><span> on July 5, 2022. Without the CT-Plan to “</span><a href="https://www.linkedin.com/pulse/new-administration-showcases-what-governance-means-kelvin-to/">outsource</a><span>” certain SEC authority to the operating committee (2/3 SROs and 1/3 Non-SROs), how will Market Data Reform likely evolve? The Self-Regulatory Organizations (SROs), including FINRA, have stated their willingness to provide part of the expanded data under the Market Data Infrastructure Rules (MDIR). Their </span><a href="https://www.ctaplan.com/publicdocs/ctaplan/CTA Odd Lots Proposal 2022.pdf">Odd-Lot</a><span> </span><a href="http
Follow the Money: What to Look for in the Market Data Infrastructure Rule s Plan Amendment
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Consolidated Audit Trail - Surveillance Without Kicking The Can Down The Road
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<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://cas