SEC Approves New Fee Model for Stock Trade Audit Trail
Published Date: 3/19/2026
Notice
Summary
The SEC approved a new way for stock market groups to pay for the Consolidated Audit Trail, a big system that tracks stock trades. This new funding plan, called the Executed Share Model, changes how fees are charged based on actual shares traded, making costs fairer for everyone involved. The changes kick in soon, so exchanges and brokers should get ready for updated fees and schedules.
Analyzed Economic Effects
5 provisions identified: 2 benefits, 3 costs, 0 mixed.
Fees Charged by Shares Traded
The SEC approved the Executed Share Model: CAT fees will be charged based on executed equivalent share volume. For each transaction, the fee for each party is calculated by multiplying the number of executed equivalent shares by one‑third and by a Fee Rate; the one‑third split applies to the Participant, the executing broker for the buyer, and the executing broker for the seller.
Two-Year Billing Sunset
The Commission limited the Executed Share Model to an interim period: the Company, the Plan Processor, and Participants may not bill or request payment of CAT Fees or Historical CAT Assessments from Industry Members after March 31, 2028. Fees billed to Industry Members before that date may still be required.
No Direct Pass-Through Fees Allowed
The amendment prohibits any Participant from filing a proposed rule change to establish a new fee that directly passes through the Participant's one‑third share of CAT costs to its members. Participants remain free to seek indirect recovery by changing existing fees, but those changes require separate Section 19(b) rule filings and Commission review.
Two Fee Types: Prospective and Historical
The amendment creates two categories of charges: Prospective CAT Fees for future operating costs and Historical CAT Assessments for past costs. Industry Members that were executing brokers will be billed for both categories. Historical CAT Costs will be reduced by excluded costs, and the Participants' one‑third share of Historical CAT Costs and other Past CAT Costs will be paid by cancellation of loans to the Company on a pro rata basis.
FINRA CAT Billing Using CAT Data
FINRA CAT will calculate CAT fees and submit invoices to CAT Executing Brokers using CAT Data. Fee billing and collection under the model are subject to satisfaction of Financial Accountability Milestones in Section 11.6 of the CAT NMS Plan.
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