The U.S. Securities and Exchange Commission (SEC) on July 11, 2012 voted to adopt new rulemaking to implement a consolidated audit trail (CAT) to monitor and analyze trading activity. The rulemaking is the result of efforts to improve market-wide surveillance stemming from the so-called “flash crash” in 2010 and more recent market events.

Rule 613 of Regulation NMS (Rule) under the Securities Exchange Act of 1934 (Exchange Act)1 will require self-regulatory organizations (SROs), including the national securities ex-changes and the Financial Industry Regulatory Authority (FINRA), to jointly create a compre-hensive CAT that will allow regulators to rapidly reconstruct trading activity in exchange-listed equity securities and listed equity options. The CAT will capture order and event information across all markets — from order inception through routing, cancellation, modification, and execution.