Yes, the CAT Funding Model is designed to collect CAT Fees related to Prospective CAT Costs (“Prospective CAT Fees”) continuously so as to provide uninterrupted funds to pay CAT bills. Accordingly, each Prospective CAT Fee will remain in place until a new Prospective CAT Fee is in effect, thereby ensuring continuous funding for the CAT. Thus, once CAT Fee 2024-1 is in effect, it is expected that there will be a Prospective CAT Fee continuously in effect going forward, with the fee rate being updated twice a year.  

For example, it is intended that the last invoice for CAT Fee 2024-1 will be provided to CAT Executing Brokers in January 2025.  The Operating Committee is then required to calculate a new fee rate for a new Prospective CAT Fee at the beginning of 2025. Once the Operating Committee has approved the new fee rate for the beginning of 2025, each of the Participants will be required to file fee filings to implement the next Prospective CAT Fee based on the new Fee Rate (i.e., CAT Fee 2025-1).  If CAT Fee 2025-1 is in effect by February 2025, then the last invoice for CAT Fee 2024-1 will be sent in January 2025, and the first invoice for CAT Fee 2025-1 would be sent in February 2025. 

However, if CAT Fee 2025-1 does not become effective by February 2025 (e.g., if the SEC temporarily suspends the filing for CAT Fee 2025-1), then CAT Fee 2024-1 will remain in effect until a new Prospective CAT Fee is in effect. CAT LLC will provide notice when CAT Fee 2024-1 will no longer be in effect.

The process for implementing a new Prospective CAT Fee at the beginning of the year will be repeated again mid-year. Updating the fee rate twice a year is intended to keep the Prospective CAT Fees closely tied to the CAT costs. For example, the Operating Committee would be required to calculate a new fee rate for the Prospective CAT Fee mid-year. Once the Operating Committee has approved the new fee rate mid-year, each of the Participants will be required to file fee filings for the new Prospective CAT Fee based on such fee rate (i.e., CAT Fee 2025-2).  Once CAT Fee 2025-2 is in effect, it would replace CAT Fee 2025-1.

This process would then repeat each year.