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- `money fact`: Citadel alleged CAT LLC held about $119 million in reserve, planned to deplete it by around August 2026, and had collected hundreds of millions under the vacated 2023 order, including more than $56 million from Citadel. Citadel also claimed roughly $16 million of the reserve was attributable to Citadel and roughly $9.7 million represented inflated reserve overage. |
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- `surveillance/privacy fact`: The motion frames CAT as a surveillance system but the immediate requested relief targets reserve spending, not data access. Citadel argues CAT can keep operating without using broker-dealer-paid reserves because SROs historically funded CAT. |
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- `governance fact`: Citadel's governance theory is that CAT LLC and SRO operators are spending regulatory fees before SEC review can occur, making later oversight meaningless. Citadel uses `Alpine` to argue that delayed SEC review is too little when the private SRO-affiliated entity's action has irreversible consequences. |
this will likely go nito about section 3 of teh govenrannce bit. it lookls like there is a tatal of 173M histocrail cat assessmen 1 costs paid and 212M left from the startup phase for the industry share. so we can portiat that out te how much SHit pai d and spcoe the progits from those percantegos
absolutely crazy they cidte Alpine after the dined wriet of certioa
SEC-Comments/S7-2026-12/11th-cir/case-docs/markdown/1-26-cv-00134/notes/high-value-filings-analysis.md
Lines 9 to 11 in fc2af56
this will likely go nito about section 3 of teh govenrannce bit. it lookls like there is a tatal of 173M histocrail cat assessmen 1 costs paid and 212M left from the startup phase for the industry share. so we can portiat that out te how much SHit pai d and spcoe the progits from those percantegos
absolutely crazy they cidte Alpine after the dined wriet of certioa