Aug. 15, 2024
Dear member of the SEC, I am writing to propose an expansion of the Consolidated Audit Trail (CAT) to include all trades, specifically incorporating Alternative Trading Systems (ATS)/darkpool trades and transactions subject to Market Maker Exemptions. The current exclusion of these trading activities from the CAT creates potential blind spots that may be exploited, undermining market integrity, transparency and investor protection. Rationale for Proposal: Comprehensive market oversight: Including ATS/darkpool trades and Market Maker Exemptions in the CAT would provide regulators with a complete picture of market activity, enhancing their ability to detect and investigate potential market manipulation, insider trading, and other illicit activities. Addressing darkpool concerns: There is growing concern that darkpool trading may be subject to abuse. By incorporating these trades into the CAT, the SEC would gain valuable insights into darkpool operations and be better equipped to identify and address any irregularities. Market Maker Exemption transparency: While Market Maker Exemptions serve a purpose in maintaining liquidity, their exclusion from the CAT creates a significant gap in market data. Including these transactions would allow for more effective monitoring of market maker activities and ensure compliance with existing regulations. Leveling the playing field: A more comprehensive CAT would help ensure that all market participants are subject to the same level of scrutiny, promoting fairness, transparency and reducing the potential for regulatory arbitrage. Improved market analysis: The inclusion of all trades in the CAT would provide more accurate and complete data for market analysis, benefiting both regulators and researchers in their efforts to understand market dynamics and develop effective policies. I believe that expanding the Consolidated Audit Trail to include all trades, particularly those currently excluded, would significantly enhance market transparency, integrity, and investor protection for all investors, including household investors. I urge the SEC to consider this proposal and take steps towards its implementation. Thank you for your attention to this matter. With appreciation, Ms. Doris Tan