The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Sat, 18 Apr 2026 11:30:34 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.8 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png Statement by Commissioner Peirce on the Costs, Risks, and Privacy Concerns of the Consolidated Audit Trail – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 Statement by Commissioner Peirce on the Costs, Risks, and Privacy Concerns of the Consolidated Audit Trail https://corpgov.law.harvard.edu/2026/04/17/statement-by-commissioner-peirce-on-the-costs-risks-and-privacy-concerns-of-the-consolidated-audit-trail/?utm_source=rss&utm_medium=rss&utm_campaign=statement-by-commissioner-peirce-on-the-costs-risks-and-privacy-concerns-of-the-consolidated-audit-trail https://corpgov.law.harvard.edu/2026/04/17/statement-by-commissioner-peirce-on-the-costs-risks-and-privacy-concerns-of-the-consolidated-audit-trail/#respond Fri, 17 Apr 2026 11:31:51 +0000 https://corpgov.law.harvard.edu/?p=180473?d=20260416154329EDT Posted by Hester M. Peirce, U.S. Securities and Exchange Commission, on Friday, April 17, 2026
Editor's Note:

Hester M. Peirce is a Commissioner at the U.S. Securities and Exchange Commission. This post is based on her recent statement. The views expressed in this post are those of Commissioner Peirce and do not necessarily reflect those of the Securities and Exchange Commission or its staff.

Today, the Commission issued a long-awaited concept release as part of its comprehensive review of the Consolidated Audit Trail (“CAT”). I hope that the comments we receive will meaningfully inform the Commission’s reassessment of the troubled and troubling CAT and prompt a broader reconsideration of our approach to financial surveillance.

The CAT, now in its teenage years, is expensive, contentious, and perilous to privacy. CAT cost overruns have been massive: the estimated annual budget of $55 million in 2016 expanded to, until very recently, an actual annual budget of almost $250 million. CAT progress has been slow; it is years behind schedule. CAT’s greatest success is its ability to generate extensive fighting among regulated entities and between regulated entities and the Commission.

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