Information Notice - 6/26/25
Executive Summary
This FINRA Information Notice announces the termination of **Prospective CAT Cost Recovery Fee 2025-1** effective July 1, 2025, with **Prospective CAT Cost Recovery Fee 2025-2** taking effect for transactions in eligible securities by FINRA member CAT executing brokers. It matters because firms must transition billing and payment processes seamlessly to avoid disruptions in CAT cost recovery compliance under FINRA Rule 6897(b)(1)(D). #
What Changed
- Termination of Fee 2025-1: No longer applied to transactions after June 30, 2025, per FINRA Rule 6897(b)(1)(D), which requires notice upon replacement by a subsequent fee. - Implementation of Fee 2025-2: New fee recovers FINRA's ~$7.27 million share of budgeted CAT costs for July 1–December 31, 2025; monthly invoicing begins for July 2025 transactions. - Distinction from CAT LLC fees: Unrelated to "CAT Fee 2025-1" (assessed by CAT LLC, rate $0.000022 per transaction, remains in effect). #
What You Need To Do
- Verify internal systems stop applying Fee 2025-1 post-June 30, 2025, and prepare for Fee 2025-2 invoicing starting July transactions
- Review and pay final Fee 2025-1 invoice (due August 2025) per Rule 6897(b)(2)
- Update budgeting/forecasting models for Fee 2025-2 (covers H2 2025 CAT costs); monitor FINRA notices for rate details via SR-FINRA-2025-010
- Contact Amanda Rath ((240) 386-6637) or Faisal Sheikh ((202) 728-8379) for questions
- Distinguish FINRA fees from CAT LLC fees to avoid double-counting in financial controls
Key Dates
Compliance Impact
Urgency: Medium - Primarily administrative; no new reporting burdens, but failure to transition could lead to underpayment, late fees, or Rule 6897 violations. Matters for high-volume brokers due to monthly cash flow impacts and ongoing CAT funding obligations (totaling FINRA's 2025 budgeted costs). As of January 2026, firms should have adapted, but audits may flag non-compliance.
Who is Affected
Summary
Information Notice - 6/26/25