Nasdaq Charges Up for Past Audit Trail Shortfalls
Published Date: 5/15/2026
Notice
Summary
Nasdaq 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 will collect about $39 million that wasn’t charged before and start right away. If you’re part of the trading world, get ready to chip in for these past expenses!
Analyzed Economic Effects
5 provisions identified: 0 benefits, 5 costs, 0 mixed.
Recover $38.96M Historical CAT Debt
Nasdaq will collect $38,964,855.34 of previously un-invoiced historical Consolidated Audit Trail (CAT) costs through a new fee called Historical CAT Assessment 1A. This amount is the remainder of a $212,039,879.34 Historical CAT Costs 1 pool that was only partially invoiced earlier.
Fee Rate: $0.000002 per Share
The fee rate for Historical CAT Assessment 1A is set at $0.000002 per executed equivalent share. For each transaction, the Historical CAT Assessment will be calculated by multiplying the number of executed equivalent shares by one-third and by the Historical Fee Rate.
Charged to CAT Executing Brokers (CEBB/CEBS)
The Assessment 1A fees will be billed to CAT Executing Brokers — the Industry Members identified as the executing brokers on the buy-side (CEBB) and sell-side (CEBS). Collectively, CEBBs are responsible for $19,482,427.67 and CEBSs are responsible for $19,482,427.67, and fees are payable to Consolidated Audit Trail, LLC (CAT LLC).
How 'Executed Equivalent Shares' Count
For billing, executed equivalent shares are counted as: each executed share in NMS Stocks = 1; each executed Listed Options contract = counted by its multiplier (for example, 100 executed equivalent shares per contract); and each executed share in OTC Equity Securities = 0.01 executed equivalent share. These counting rules determine how many units are multiplied by the fee rate.
Invoice Timing: June 2026 Start
CAT Executing Brokers will receive their first monthly invoice for Historical CAT Assessment 1A in June 2026, and that invoice will be calculated based on transactions they executed in May 2026. Monthly invoicing will follow thereafter.
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Key Dates
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Nasdaq PHLX 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 for costs before 2022 that weren’t billed before. The fees kick in right away and are charged per share traded, so traders should get ready to chip in!
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