The SEC requested comments on proposed Rule 613 to establish a Consolidated Audit Trail ("CAT") estimated to take 3 years to develop at a cost of $4 Billion year one and $2.1 Billion a year thereafter. In its comment letter, FTEN explained that FTEN's At-Trade™ secure data cloud system already provides real-time, market-wide transparency, accountability and control on a private party basis for major market participant clients and that a decision to use FTEN's At-Trade secure data cloud to satisfy CAT goals of real-time cross-market transparency, accountability and control would provide the following benefits:

• Immediate Availability / No Implementation Risk
  FTEN's At-Trade secure data cloud would provide immediate full market coverage with no implementation risk (up to 73% of the market could be covered within 30 days)
• Full Cross-Market / Cross-Asset Coverage
  FTEN's At-Trade secure data cloud was architected from inception to process in real-time all electronically traded securities and to incorporate information for all electronically reported securities and currently covers all securities under the jurisdiction of the SEC.
• Facilitate Cooperation Among Regulators
  FTEN's At-Trade secure data cloud would provide regulatory agencies with the flexibility to focus on their independent jurisdictional mandates while also facilitating cooperation, data sharing and potential "roll-up" of information between domestic U.S. regulators and / or international counterparts.
• Reduced Burden on Individual Investors
  FTEN's At-Trade secure data cloud approach could be provided for a dramatically lower cost than that estimated by the SEC and would represent a new source of information available to market participants which could enable new products and services to be provided to market participants which could underwrite much, if not all, of the cost of CAT.
  
• Additional Benefits to Market Participants
  CAT could be enhanced to provide additional functionality and to accommodate new regulatory objectives. For example, CAT could provide real-time risk management and counter-party awareness to address SEC Rule 15c3-5 Market Access concerns like naked / sponsored access, help resolve allocation issues, serve as a real-time conduit to coordinate "circuit breaker" responses across markets and asset classes, address objectives of the SEC Large Trader Reporting System, serve as an industry-wide securities master file and serve as a framework to be leveraged by other regulatory agencies (e.g., the new Office of Financial Research as well as the U.S. Commodity Futures Trading Commission) to avoid unnecessary duplication of effort and potential regulatory fragmentation. Done correctly, CAT could even help firms enhance their internal operational efficiencies thereby strengthening the competitiveness and viability of our financial markets and helping to restore individual investor confidence.
  
  To read FTEN's CAT comment letter to the SEC click here
  
  To read FTEN's 2004 Strategic White Paper entitled "Time Equals Risk"
  that was written a year after development of the Intraday RiskXposure
  technology in 2003 to support the At-Trade secure data cloud click here