Statement at SEC Open Meeting: Consolidated Audit Trail
Commissioner Daniel M. Gallagher
U.S. Securities and Exchange Commission
July 11, 2012
Thank you, Chairman Schapiro. I’d like to join my colleagues in expressing gratitude to the staff for the tremendous amount of work that went into this rulemaking, and the tremendous quality of the work product. This has truly been a collaborative effort, with staff from various Divisions and Offices pooling their experience, talents, and knowledge, and working closely together over a span of years.
I’d particularly like to convey my sincere appreciation to Robert Cook and the Division of Trading and Markets staff for their dedication and effort throughout the rulemaking process and, especially, over the past several weeks. I know that it has been an extraordinarily demanding time for the staff, and I am grateful for your unflagging - and uncomplaining - efforts in shepherding this release across the finish line. This rulemaking has enabled the Division to showcase some of the incredibly and uniquely talented staff that have joined over the last few years, and in that vein I would like to note the significant contributions of Gregg Berman.
I’d also like to take a moment to recognize the contributions of John Polise, who has been an intellectual and motivational force behind this rulemaking over the last three years.
And finally, I want to recognize Chairman Schapiro for her leadership in pressing for a consolidated audit trail. The Chairman’s support of CAT has been unwavering, from three years ago when it was simply an idea in a memo, to this final rulemaking today. That commitment, along with a willingness to reconsider aspects of the rule proposal that would have been unduly burdensome in favor of a more flexible and incremental approach, is the reason we are here today.
Throughout this rulemaking I have often said that if I asked my neighbors or my relatives whether they thought the SEC had access to the types of information that will be included in the consolidated audit trail, the response would be: “of course.” After all, as the primary regulator of our securities markets, why wouldn’t the SEC have comprehensive information on all market activity?
The NMS plan that will be required pursuant to today’s rulemaking will ensure that in the near future, we will indeed have the information we need to smartly regulate today’s complex markets, and aid us in monitoring and overseeing those markets. To be clear, this rule is a sea-change for the securities markets – it requires the reevaluation and revamping of key aspects of market infrastructure; it will provide the Commission with data and other information that is critical to satisfying our statutory missions, and allowing us to oversee the markets in a smart and efficient manner.
If it were not for the Dodd-Frank rulemaking frenzy that has dominated the SEC’s agenda for the last two years, it would be abundantly clear that this rulemaking is a game changer. CAT is a tremendous step forward for the Commission, for the securities markets, and for investors, and I am pleased to support it.
I have no questions.