Business Clock Synchronization Practices,

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<p id="14c6dee3-1d9d-4d7d-8237-5e35dd57d115">As discussed above, the Participants do not believe that it is necessary or appropriate to amend the Business Clock synchronization requirements set forth in the Plan at this time. The Participants will reassess whether the Business Clock synchronization requirements remain consistent with industry standards &#8211; or whether it may be necessary to amend such requirements &#8211; in the future as part of the annual assessment required by <a href="CAT NMS Plan, Article VI - Functions and Activities of CAT System, Timestamps and Synchronization of Business Clocks">Section 6.8(c) of the Plan</a>. To make such an assessment, the Participants intend to continue working with the Advisory Committee and the industry generally, including CAT Reporters of various sizes and types, to determine whether current Business Clock synchronization practices have changed sufficiently to suggest that narrower synchronization thresholds may be consistent with industry standards. As the Commission noted when it approved the Plan, if the Participants determine based on a future assessment that the clock synchronization requirements in the Plan should be changed, the Participants would need to file a proposed amendment to the Plan with the Commission. Such a submission would enable the Commission, as well as Industry Members and the public, to evaluate the proposed requirements, including anticipated costs, benefits and related implementation time frames.</p>

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<p>1 The CAT NMS Plan is a national market system plan approved by the Commission pursuant to Section 11A of the Exchange Act and the rules and regulations thereunder. See <a href="Order Approving the Consolidated Audit Trail Plan Release 34-79318">Securities Exchange Act Release No. 79318 (Nov. 15, 2016)</a>, <a href="https://www.federalregister.gov/citation/81-FR-84696">81 Fed. Reg. 84696 (Nov. 23, 2016)</a> (the &#8220;Adopting Release&#8221;). The full text of the CAT NMS Plan is available at <a href="http://www.catnmsplan.com">www.catnmsplan.com</a>.</p>

<p id="aa30096d-feb0-4962-821d-1d056212da66">&#8226; 8:00 a.m. Eastern Time T+5 (transaction date + five days) &#8211; Corrected data available to Participant regulatory staff and the SEC.</p>

<p id="a777ef0c-8942-4ada-9ece-6d314de02b2e">Late submissions or re-submissions (after 8:00 a.m.) may be considered to be processed that day if it falls within a given time period after the cutoff. This threshold will be determined by the Plan Processor and approved by the Operating Committee. In the event that a significant portion of the data has not been received as monitored by the Plan Processor, the Plan Processor may decide to halt processing pending submission of that data.</p>

<p id="aaf19f05-5926-483e-b18a-99535c850ea8">Figure A: CAT Central Repository Data Processing Timelines</p>

<p id="0b0488f0-a7c2-456f-a2ec-c187ccdc4c75">6.2 Data Availability Requirements</p>

<p id="689bfb39-8b30-4211-b166-a2a3427e6344">Prior to 12:00 p.m. Eastern Time on T+1, raw unprocessed data that has been ingested by the Plan Processor must be available to Participants&#8217; regulatory staff and the SEC.</p>

<p id="26a7e061-8e96-4213-9476-27f49628841b">Between 12:00 p.m. Eastern Time on T+1 and T+5, access to all iterations of processed data must be available to Participants&#8217; regulatory staff and the SEC.</p>

<p id="c894b017-7115-47c3-8951-b3aa1cbd4aca">The Plan Processor must provide reports and notifications to Participant regulatory staff and the SEC regularly during the five-day process, indicating the completeness of the data and errors. Notice of major errors or missing data must be reported as early in the process as possible. If any data remains un-linked after T+5, it must be available and included with all linked data with an indication that the data was not linked.</p>

<p id="add8c0c0-8469-477e-ab92-a2c2a0377c20">If corrections are received after T+5, Participants&#8217; regulatory staff and the SEC must be notified and informed as to how re-processing will be completed. The Operating Committee will be involved with decisions on how to re-process the data; however, this does not relieve the Plan Processor of notifying the Participants&#8217; regulatory staff and the SEC.</p>

<p id="508e353f-b07b-41db-995a-0fafae482b9e">Figure B: Customer and Account Information (Including PII)</p>

<p id="37119199-6f0c-4850-9419-a08ea8fa4af2">CAT PII data must be processed within established timeframes to ensure data can be made available to Participants&#8217; regulatory staff and the SEC in a timely manner. Industry Members submitting new or modified Customer information must provide it to the Central Repository no later than 8:00 a.m. Eastern Time on T+1. The Central Repository must validate the data and generate error reports no later than 5:00 p.m. Eastern Time on T+1. The Central Repository must process the resubmitted data no later than 5:00 p.m. Eastern Time on T+4. Corrected data must be resubmitted no later than 5:00 p.m. Eastern Time on T+3. The Central Repository must process the resubmitted data no later than 5:00 p.m. Eastern Time on T+4. Corrected data must be available to regulators no later than 8:00 a.m. Eastern Time on T+5.</p>

<p id="d9b40e30-5ff3-434e-a648-2c3bc5f18394">Customer information that includes PII data must be available to regulators immediately upon receipt of initial data and corrected data, pursuant to security policies for retrieving PII.</p>

<p id="4b26a299-798c-48ad-aa02-d487e817cb99">7. Receipt of Data from Reporters</p>