Nasdaq Texas Bills Traders for Old Audit Trail Debts
Published Date: 5/15/2026
Notice
Summary
Nasdaq Texas is setting new fees for industry members to cover leftover historical costs from the National Market System Plan for the Consolidated Audit Trail. These fees, called Historical CAT Assessment 1A, will collect about $39 million that wasn’t billed before. The new charges start right away and will be added to the Exchange’s fee schedule, so members should get ready to pay a tiny fee per trade executed.
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Analyzed Economic Effects
5 provisions identified: 1 benefits, 3 costs, 1 mixed.
Who bears the remaining costs
The remaining $38,964,855.34 of Historical CAT Costs 1 will be recovered from CAT Executing Brokers collectively, with buy-side executing brokers (CEBBs) responsible for $19,482,427.67 and sell-side executing brokers (CEBSs) responsible for $19,482,427.67.
Participants' share paid by loan cancellation
Participants (the exchanges) will not be invoiced for the Participants' one-third share of Historical CAT Costs 1; instead, their one-third share ($106,019,939.67 in total for Historical CAT Costs 1) will be paid by cancellation of loans the Participants previously made to CAT LLC on a pro rata basis. Participants remain 100% responsible for certain Excluded Costs.
New per-share CAT historical fee
Nasdaq Texas (on behalf of CAT LLC) is charging Industry Members a Historical CAT Assessment 1A to recover $38,964,855.34 of leftover historical Consolidated Audit Trail costs. The fee rate is $0.000002 per executed equivalent share and will appear in the Exchange fee schedule under "Consolidated Audit Trail Funding Fees." CAT Executing Brokers will receive their first invoice in June 2026 for May 2026 transactions.
How fees are calculated per transaction
The Historical CAT Assessment 1A will be charged per transaction by multiplying executed equivalent shares by the Historical Fee Rate. Executed equivalent shares are counted as: 1 per executed share for NMS Stocks, the option contract multiplier (e.g., 100) for Listed Options, and 0.01 per executed share for OTC Equity Securities.
Possibility of passing fees to customers
The filing notes that the Commission recognized Industry Members may pass-through CAT fees for customer-executed volume. That means brokers could choose to pass some or all of the per-share Historical CAT Assessment cost onto their customers' trades.
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