Consolidated Audit Trail (“CAT”) Clock Synchronization Requirements

On November 15, 2016, the Securities and Exchange Commission (“SEC”) approved the National Market Plan Governing the Consolidated Audit Trail (the “CAT NMS Plan” or the “Plan”). Pursuant to the CAT NMS Plan, each national securities exchange and the Financial Industry Regulatory Authority, Inc. (“FINRA”) (each, a “Participant” in the Plan) has filed with the SEC a compliance rule series that requires the Participant’s members to comply with the CAT NMS Plan requirements and, ultimately, to report information to the CAT. The Participants are issuing this alert in anticipation of the SEC’s approval of the Participants’ compliance rule series.