Emerald's Audit Fee Flip: More Micro-Charges Incoming
Published Date: 7/11/2025
Notice
Summary
Starting July 1, 2025, MIAX Emerald is updating its fee schedule to charge industry members a new, lower fee of $0.000009 per share for the Consolidated Audit Trail (CAT) costs. This fee helps cover half the budgeted expenses for CAT from July through December 2025, replacing the previous higher fee. Brokers will see their first bill in August based on July trades, so get ready to keep those records sharp and fees clear!
Analyzed Economic Effects
4 provisions identified: 1 benefits, 3 costs, 0 mixed.
New CAT Fee for Executing Brokers
Starting July 1, 2025, MIAX Emerald will assess a Consolidated Audit Trail (CAT) fee called CAT Fee 2025-2 of $0.000009 per executed equivalent share to CAT Executing Brokers (CEBBs and CEBSs). CAT Executing Brokers will receive their first monthly invoice in August 2025 based on their July 2025 transactions.
Fee Replaces Higher Prior CAT Charge
CAT Fee 2025-2 at $0.000009 per executed equivalent share replaces the prior CAT Fee 2025-1, which had a fee rate of $0.000022. The change results in a lower per-share fee for Industry Members compared with the prior fee filing.
Budget and Cost Allocation for July–Dec 2025
MIAX reports budgeted CAT costs for July 1–December 31, 2025 of $60,726,412. CEBBs collectively are allocated one-third of those Budgeted CAT Costs ($20,242,137.33) and CEBSs collectively are allocated one-third ($20,242,137.33); CAT Fee 2025-2 is anticipated to recover approximately one-half of the reasonably budgeted CAT costs for 2025.
Brokers May Pass CAT Fee To Clients
The filing states that CAT Executing Brokers (CEBBs/CEBSs) may, but are not required to, pass-through their CAT Fees to their clients; those clients may in turn pass fees to their clients until the fee is imposed on the account that executed the transaction. This means retail or institutional clients could see transaction-level charges related to CAT fees.
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Previous: 2025-12920 — Self-Regulatory Organizations; MIAX PEARL, LLC; Notice of Filing and Immediate Effectiveness of a Proposed Rule Change To Amend the Fee Schedule To Establish Fees for Industry Members Related to Reasonably Budgeted Costs of the National Market System Plan Governing the Consolidated Audit Trail for the Period From July 1, 2025 Through December 31, 2025
Starting July 1, 2025, MIAX PEARL will charge industry members a new, lower fee of $0.000009 per share to help cover the costs of the Consolidated Audit Trail system. This fee replaces the older, higher fee and will last through the end of December 2025. Brokers will see their first bill in August based on July trades, so get ready to budget for this update!
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