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FAQs

What is the CT Plan?
The CT Plan is the new national market system (“NMS”) Plan to govern the public dissemination of real-time consolidated equity market data for NMS stocks. The CT Plan will be the unified successor to the existing three market data equity Plans – CTA/CQ and UTP.
The CT Plan was established pursuant to a 2023 order by the Securities and Exchange Commission (“SEC”) that directed the U.S. equities exchanges and FINRA to act jointly in developing a new single national market system Plan to govern the public dissemination of real-time consolidated equity market data. The new CT Plan is intended to deliver greater efficiency to the industry by streamlining the administrative functions associated with running a consolidated market data feed.
The CT Plan is expected to begin disseminating data in Q2 2027. A project tracker has been created that details all steps being taken to create the new Plan.
The CT Plan will be the successor to the current three NMS Plans (CTS, CQS and UTP Plans) to (CTA/CQ and UTP Plans), which will be phased out following CT Plan’s expected Q2 2027 launch. The biggest change for the industry will be dealing with a single entity, with one Administrator, one set of rules, one set of auditors, etc. While specifics will be provided in due course, they will be phased out with plenty of notice and in close consultation with the industry to ensure minimal disruption to market participants’ businesses. Those interested in being kept abreast of relevant developments should register to receive email updates as they are published or check the progress tracker.

Similar to the three Plans it will eventually replace, the CT Plan will be run by an Operating Committee that consists of all the U.S. equity exchanges and FINRA.

The Operating Committee has an Advisory Committee comprised of professionals from a cross-section of the financial industry. 

The Administrator will be selected by the Operating Committee. An RFP for the role of Administrator has been released, with a goal of selecting and contracting one by Q1 2026.

Who are the participants in the CT Plan?
The Members listed in Exhibit A of the Plan.
The governance of the CT Plan is outlined in Article IV of the Plan.
The Administrator is outlined in Article VI of the Plan.
When will the CT Plan go into effect?

There are a number of steps that must be completed prior to the CT Plan going into effect, which are outlined in the progress tracker.

The specific timeline will be provided as we get closer to the transition date.
Data dissemination will not change prior to or after the transition period. The data will continue to be disseminated via the current processors.
As the implementation date gets closer, the market participants will be notified of any actions required of them.
Will there be changes to the data feed formats or APIs?
There will be no changes to data feed formats with this transition. Other SIP initiatives – such as support for 24×5 trading or Odd Lots – may necessitate some changes to data feeds, but the move to the new CT Plan is a transition solely for the Administrator.
There will be no changes to latency, resiliency or capacity. The move to the new CT Plan is a transition solely for the Administration of the Plan.
No testing or certifications will be required. The move to the new CT Plan is a transition solely for the Administration of the Plan.
Will the fee structure for market data change?
The Operating Committee will submit a proposed fee schedule to the SEC by November 2025. The fees must be approved by the SEC before they can become effective.
New fees will be filed with the SEC and sent for public notice and comment.
How can the public access CT Plan data?
There will be no change to the means by which market participants can access SIP data, which means the current freely available data (15-minutes delayed) will remain. The move to the new CT Plan is a transition solely for the Administration of the Plan.
Information related to the CT Plan can be found on our website. The initial site was launched in September 2025, and additional information will be made available through it as it becomes available.

Stakeholders are encouraged to contact the Operating Committee through our communications partner (CTPlan@forefrontcomms.com) or their relevant Advisory Committee member.