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Self-Regulatory Organizations; Nasdaq GEMX, LLC; Notice of Filing and Immediate Effectiveness of Proposed Rule Change To Establish Fees for Industry Members Related to Reasonably Budgeted CAT Costs of the National Market System Plan Governing the Consolidated Audit Trail for May 1, 2026 Through December 31, 2026

Thursday, May 14, 2026

Plain English Summary

Starting May 1, 2026, Nasdaq GEMX will implement new fees for industry members to cover the costs of the Consolidated Audit Trail (CAT). These fees will help pay for necessary insurance policies, including cybersecurity, directors and officers liability, and errors and omissions insurance. These types of insurance are standard for companies and are crucial for protecting the CAT system. Insurance agents should be aware of these changes and prepare to inform their clients about the potential impact on costs.
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3(a)(2)(C) above. It is anticipated that the <span class="match">insurance</span> costs for CAT during the CAT Fee 2026-1 Period will include costs related to cyber security liability <span class="match">insurance</span>, directors' and officers' liability <span class="match">insurance</span>, and errors and omissions liability <span class="match">insurance</span> brokered by USI <span class="match">Insurance</span> Services LLC (“USI”). Such policies are standard for corporate entities, and cyber security liability <span class="match">insurance</span> is important for the CAT System. CAT LLC anticipates that it will continue to maintain this <span class="match">insurance</span> during the CAT Fee 2026-1 Period, and notes that