Sep. 18, 2026
To the Securities and Exchange Commission, Re: File 4-927; Release 34-106402 - technical comment on notice history and transaction-publication evidence CSOAI Ltd develops measurement and evidence tooling. This comment is limited to the observability of the public-notice, transaction-transparency and trading-stoppage conditions in sections II.C, II.G and II.H. It does not offer a view on the overall merits or duration of the exemptions, assert that any venue is non-compliant, or request adoption of CSOAI. Section II.G requires transaction data to be updated within ten minutes of the occurrence of any transaction. That is not merely a requirement to refresh a webpage periodically. The following reporting details would help outside readers interpret the resulting evidence without treating an observer's collection delay as a venue's publication delay. 1. Distinguish transaction time, publisher-reported publication time, independently observed availability and collection time. State clock uncertainty and the basis of each timestamp where available. A third party first seeing a record after twelve minutes does not, without further evidence, establish that the record was first published after twelve minutes. Seeing it by nine minutes can support an upper bound on availability at that observation point, subject to the transaction-time evidence. Neither observation alone establishes equal access for every participant. 2. Preserve stable event and instrument references alongside the fields already required by II.G. A practical export could reference the venue, pool/contract and network, asset pair, event identifier and revision. A trade republished in two snapshots should remain one trade rather than two independent observations of economic activity. Reuse established identifiers where suitable instead of mandating a new vendor namespace. 3. Make collection scope and unresolved evidence explicit. The thirty-day data window, collection interval, available partitions and pagination completion should remain distinguishable. An empty interval is not by itself evidence that no trade occurred; a failed or partial retrieval is not a complete census. Conversely, an absence should not be labelled a missing trade unless there is evidence of the expected trade or population. 4. Preserve amendments and their relationship to earlier records. Section II.C already requires notice versions to remain available. A machine-readable revision identifier, effective time, change category and predecessor reference could make those versions easier to compare. The same discipline would help distinguish a corrected transaction record from a new transaction. A later signature or retrieval must not relabel an earlier underlying observation as freshly measured. 5. For II.H, retain the reference stoppage, relevant venue action and evidence of scope. An announcement that trading stopped, a command to stop, and observed cessation are distinct. Lack of observed trading alone does not prove an enforced stop. Operational logs or owner-authorised test evidence may be necessary; confidential records need not be placed in a public log merely to support review. Illustrative synthetic controls are: timely observed availability; late first observation with unknown earlier availability; a stipulated first-publication time beyond the limit; and clock bounds that straddle the limit. They should yield distinct, scoped outcomes rather than one binary compliance label. These examples are design controls, not empirical findings about any operating venue. We suggest encouraging interoperable field definitions and examples, and measuring implementation burden in a pilot. We have not established that the proposed metadata is cost-free or sufficient for a regulatory determination. Hashes and signatures may support record integrity; they do not establish the accuracy of a reported event, completeness, reserve adequacy or legal compliance. Source reviewed: https://www.sec.gov/files/rules/exorders/2026/34-106402.pdf - sections II.C, II.G, II.H and VI; transaction-transparency text on printed pages 28-29. This is a focused technical reading, not an exhaustive legal review of the order. Disclosure: CSOAI is developing measurement/evidence tooling and exploring related commercial work, so we have an interest in this area. No Commission endorsement, accreditation or partnership is claimed. Nicholas Templeman Founder, CSOAI Ltd nicholas@csoai.org