FINRA Makes Brokers Pay for Old Audit Trail Costs
Published Date: 5/18/2026
Notice
Summary
FINRA is updating its rules to charge industry members fees for leftover historical costs of the Consolidated Audit Trail system that weren’t covered before. If you’re part of the financial industry, expect to pay your share of about $39 million in fees starting now. This change kicks in immediately to wrap up past expenses and keep the system running smoothly.
Analyzed Economic Effects
4 provisions identified: 1 benefits, 3 costs, 0 mixed.
Participants' one-third paid by loan cancellation
Participants (the exchanges and other Plan Participants) will not be assessed the Historical CAT Assessment; instead, Participants collectively remain responsible for one-third of Historical CAT Costs 1 (which is $106,019,939.67) and that share will be satisfied by cancellation of loans made by the Participants to CAT LLC. Participants also remain 100% responsible for certain Excluded Costs of $83,253,090.
Industry Members billed $38.96M
If you are an Industry Member (a member of a national securities exchange or national securities association), FINRA will charge Industry Members a collective $38,964,855.34 for leftover historical Consolidated Audit Trail (CAT) costs. The fee rate is $0.000002 per executed equivalent share and CAT Executing Brokers will receive their first monthly invoice in June 2026 for May 2026 transactions.
Which brokers pay and allocation
The Historical CAT Assessment 1A will be charged to CAT Executing Brokers for the Buyer (CEBB) and for the Seller (CEBS). The $38,964,855.34 remaining balance will be split so CEBBs collectively are responsible for $19,482,427.67 and CEBSs collectively are responsible for $19,482,427.67.
How fees are calculated per share
The Historical CAT Assessment is calculated per executed equivalent share: NMS stock executed shares count as 1, listed options are counted by the applicable contract multiplier (e.g., 100), and OTC equity executed shares count as 0.01. For each transaction the assessment is calculated by multiplying the number of executed equivalent shares by one-third and then by the Historical Fee Rate of $0.000002.
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Previous / Next Documents
Previous: 2026-09853, Self-Regulatory Organizations; 24X National Exchange LLC; Notice of Filing and Immediate Effectiveness of Proposed Rule Change To Establish Fees for Industry Members Related to Certain Historical Costs of the National Market System Plan Governing the Consolidated Audit Trail
24X National Exchange 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 charged before. The new charges start right away and help pay for past expenses that keep the market running smoothly.
Next: 2026-09855, Self-Regulatory Organizations; Nasdaq MRX, LLC; Notice of Filing and Immediate Effectiveness of Proposed Rule Change To Establish Fees Related to Certain Historical Costs of the National Market System Plan Governing the Consolidated Audit Trail
Nasdaq MRX is setting new fees to cover leftover historical costs from the National Market System Plan for the Consolidated Audit Trail that weren’t paid before 2022. Industry members who trade shares will now pay a tiny fee per share to help cover nearly $39 million in past expenses. These fees kick in right away and show up on the Exchange’s fee schedule under a new category.