Subject: File 4-927 - CSOAI technical comment on notice history and transaction-publication evidence
From: Nicholas Templeman
Affiliation:

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