No, primary market transactions, as defined in Section 1.1 of the Plan, are not subject to CAT reporting. The Participants analyzed whether to include primary market transactions in the CAT, and concluded doing so was premature and that such an analysis would benefit from actual experience with the CAT. See Discussion of the Potential Expansion of the Consolidated Audit Trail Pursuant to Section 6.11 of the CAT NMS Plan (May 15, 2017) (available at Expansion Report).