The change is required by the SEC. In May 2020 the SEC adopted the Governance Order (SEC Release No. 34-88827), directing the US National Market System exchanges and FINRA to file a single new national market system plan to replace the separate CTA and UTP Plans with one consolidated governance structure. The order was later amended in September 2023.
How the CT Plan came together:
- May 2020 — SEC adopts the Governance Order mandating a single plan
- September 2023 — the order is amended
- 2024 — CT Plan LLC approved as the oversight organization, its members forming the Operating Committee
- 2025 — DataCT LLC appointed as the new Independent Administrator
- December 2025 — the new Fee Schedule is filed for approval
- June 2026 — the SEC approves the Fee Schedule for implementation from the Operative Date