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4 changes: 4 additions & 0 deletions S7-2026-12/com-opposititon/RH-SRC_MAIN.md
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"inadvertent technical errors are foreseeable"
https://www.sec.gov/comments/S7-2026-12/s7202612-883899-2689254.pdf

as 'tardy camment' and then it's a simele backrof to 'timely' Trade385 nn.
9 changes: 9 additions & 0 deletions S7-2026-12/coreArgs/linkage-process-oss.md
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basis

https://github.com/sec-gov/oes/pull/2
https://github.com/sec-gov/oh/pull/13


---

it',s treriras to seporte the data frmo the actial Lambda funcitons they litery dir src qute }} say that thaey''re using
36 changes: 36 additions & 0 deletions S7-2026-12/coreRefs/budget-specififcity--hence-oversight.md
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https://chatgpt.com/c/6a47ff9e-dcd4-83ea-ba99-5d968effb906 has some sels:

> Yes, but only at a fairly generic level. For Peak Strategies, the filing says the firm performed:

“media relations consulting, strategy and execution”;
monitoring congressional efforts concerning CAT;
monitoring public comments and reactions to CAT proposals;
monitoring press coverage;
reporting those developments back to CAT LLC;
drafting and distributing public communications; and
communicating developments such as amendments to the CAT NMS Plan.

>>> ---

https://www.sec.gov/files/rules/sro/24x/2026/34-105469.pdf ids the src from 46 on they spned _at lesat_? $57,000 on PR
(at 37)[^1]

that is ovouhly not a reglutary requrimenut, and it is very jusoitnable if it shol dbe paid fo r by the pebss-ic c

mty thinknig on a drop-cut-turn is:

> THe CAT [tecm for SRO: ontettitiy which is not the llegal ssubstasnce or the LLC asn finra] .{fn}
>
> {fn} - See., eg, ekpneoditicures of %{exact}$ incurred [befroe the CAT even cawhme into exisntenctec (no but that overlapns so that's bad)] hiriing xy PR in disc.doc, AA ^^ (form https://www.sec.gov/files/rules/other/2022/34-95235-public-appendix-1.pdf).

[^1]: no lelizerables ```Yes, but only at a fairly generic level. For Peak Strategies, the filing says the firm performed:

“media relations consulting, strategy and execution”;
monitoring congressional efforts concerning CAT;
monitoring public comments and reactions to CAT proposals;
monitoring press coverage;
reporting those developments back to CAT LLC;
drafting and distributing public communications; and
communicating developments such as amendments to the CAT NMS Plan.

So, practically, they were doing press monitoring, political/public-comment monitoring, internal briefing, messaging, and media relations.```
36 changes: 36 additions & 0 deletions S7-2026-12/curr-left.md
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# Priority

## High

- https://www.sec.gov/comments/S7-2026-12/s7202612-859219-2647946.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-908240-2776683.pdf at 6 as opposition
- https://www.sec.gov/comments/S7-2026-12/s7202612-868292-2668936.pdf aT 5 (natianoivaitno)
- https://www.sec.gov/comments/S7-2026-12/s7202612-858119-2645066.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-860419-2651836.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-859759-2649426.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-859379-2648516.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-860099-2650652.pdf

## Med

- https://www.sec.gov/files/rules/other/2022/34-95235-public-appendix-1.pdf --> https://www.sec.gov/files/rules/other/2022/34-95235-public-appendix-2.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-858679-2646728.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-859699-2649246.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-859539-2648993.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-857619-2643308.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-859459-2648706.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-860379-2651538.pdf (https://discord.com/channels/1102309240145707049/1102309240741310503/1521913782551707949)
- https://www.sec.gov/comments/S7-2026-12/s7202612-859601-2649095.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-858000-2644652.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-858619-2646612.pdf

## Low

- https://www.sec.gov/comments/S7-2026-12/s7202612-896759-2722280.html (dual cass intro)
- https://www.sec.gov/comments/S7-2026-12/s7202612-859639-2649110.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-860919-2653517.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-862239-2659701.pdf (builds on ' 16)
- https://www.sec.gov/comments/S7-2026-12/s7202612-858239-2645433.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-858001-2644690.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-865207-2665219.pdf
- https://www.sec.gov/comments/S7-2026-12/s7202612-858859-2646988.pdf
18 changes: 18 additions & 0 deletions S7-2026-12/finra-efforts/settlement.md
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TECHKNCIALLY this is the OpCo but it makse sense here for ogirinigving theri budfget requesnns

if they can sepnetd this much on nothing, they dhave llevsss basisi teu chanleleng inedusef-stanadfgr cloud comepcuitng



The **extra $9.389 million was primarily arbitration lawyers and arbitration-administration costs**, not another payment to Thesys:

**$14,749,362 total termination/arbitration costs**
− **$5,360,366 settlement awarded to Thesys**
= **$9,388,996**

The filing identifies that remainder as:

* fees to the **American Arbitration Association**
* **Pillsbury’s legal fees** for prosecuting and defending the Thesys arbitration

https://www.catnmsplan.com/sites/default/files/2021-08/CAT-NMS-LLC-2019-and-2018-Financial-Statements.pdf
34 changes: 34 additions & 0 deletions S7-2026-12/last-comms.md
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- https://www.sec.gov/comments/S7-2026-12/s7202612-851919-2613995.pdf
- into's Relue 611 at 1
- https://www.sec.gov/comments/S7-2026-12/s7202612-848339-2599616.pdf
- CAT AOMS https://discord.com/channels/1102309240145707049/1520170779348697098
- https://www.sec.gov/comments/S7-2026-12/s7202612-843759-2586026.html
- repats the acatdemitc claims in modern contetktt
- "the Commission should invest in expanding its capabilities and explore mechanisms for releasing aggregated, anonymized, and privacy-protected market data to the public. Greater transparency would improve market confidence, enhance independent oversight, encourage academic research, and reduce the information advantages currently enjoyed by dominant market participants."
- APEX https://www.sec.gov/comments/S7-2026-12/s7202612-859919-2650328.pdf
- calls for more SLAs at 4
- want cat keyed to ccid fdid
- Large Options Positions Report at 5
- there's pretty s imllpe backref te toh seegmentnofdf opne-sonerceincg corecpts in PREV (OCC1) which thwen ektine d to the DEX deffirinteitnatin
- thde latter will be a whole bit teo ektrapale seperate from a CAT LLC sintce i'nt's not corpoctavied
- at 7: "Effective supervision of CAT reporting requires firms to compare their internal order andtrade records against what their reporting agents actually submit to the CAT. In practice, there is nostandardized mechanism for performing this comparison. Firms must build their ownreconciliation processes, often from scratch, to compare internal records against report card data,portal feedback, and, where available, reporting agent output files. The absence of standardized reconciliation tools means that even firms with well-resourcedcompliance functions face a significant build burden before they can perform the comparativereviews that regulators expect."
- refs https://www.finra.org/rules-guidance/notices/20-31 which can ekapnad to the fill repceutr caards
- https://www.sec.gov/comments/S7-2026-12/s7202612-859219-2647946.pdf NYSE
- letpetas the claim of needing the data to reguleito at 2
- "Access to comprehensive and complete audit trail information is essential to the NYSE Exchanges’
ability to fulfill their regulatory obligations as SROs, chiefly NYSE Regulation’s ability to identify
market participants who are engaged in fraud, market manipulation, or other behaviors that harm
investors or disrupt the fair and orderly operation and integrity of the securities markets."
- "Thus, without the CAT, the NYSE Exchanges’ ability to satisfy their obligations to conduct basic
market surveillance, identify parties responsible for manipulative trading, and prevent systemic
abuses would be significantly impeded."
- at 4 they support 1F1V "Altering the voting structure in a way that undermines
the one SRO, one vote principle risks divorcing regulatory responsibility from governance
authority."


:Opposisetn
- the Davidson plantiffs ! https://www.sec.gov/comments/S7-2026-12/s7202612-843399-2584626.pdf
- calls SRO fees a tex whoppee CITES 25 case https://www.sec.gov/comments/S7-2026-12/s7202612-856519-2636008.pdf 9and majqaco eqjqutonss yay)


3 changes: 3 additions & 0 deletions S7-2026-12/postponed/README.md
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Expand Up @@ -93,3 +93,6 @@ Oppositoin I don''t like or care aabout enght to parse:
- FIF 2 https://www.sec.gov/comments/4-698/4698-641207-1918454.pdf
- FIF 3 https://www.sec.gov/comments/4-698/4698-702007-2205454.pdf
- https://www.sec.gov/comments/4-698/4698-608327-1776534.pdf

And then the incomnig final comments:
-