Creation of NMS Plan

Going back to 2010, in the immediate wake of the Flash Crash, the Securities and Exchange Commission (SEC) began working on a rule to develop the CAT -- a modern system to track comprehensive information associated with U.S. equities and options trading. The CAT is intended to enable regulators to oversee our securities markets on a consolidated basis—and in so doing, better protect markets and investors.

The SEC’s final rule -- Rule 613 -- was adopted with bi-partisan support in July 2012. In broad strokes, the rule requires the SROs to jointly submit a plan -- called an NMS plan -- to create, implement, and maintain a consolidated audit trail. The CAT improves on existing systems by significantly increasing the information on listed options, by providing additional details for better tracking orders as they traverse the markets, and by adding the ability to identify the individuals involved in trading activity.

In November of 2016, the SEC unanimously approved the CAT NMS Plan, and in January of 2017, following a multi-party bid process, Thesys Technologies was selected to develop, implement and operate the CAT through a separate affiliate that was later formed as Thesys CAT LLC (Thesys CAT).

On April 6, 2017, CAT NMS and Thesys CAT reached a contractual agreement, known as the Plan Processor Agreement (“PPA”). Thesys CAT has its own management team, separate from Thesys Technologies, in order to provide information barriers between CAT-related activities and other activities of Thesys Technologies.

Thesys CAT has since taken this opportunity to apply its advanced high-performance technology and know-how to meaningfully upgrade the regulatory infrastructure of the markets -- a powerful expression of our mission of “better markets through technology”.

Management Team

Andre Frank

President, Thesys CAT LLC

Andre Frank is currently President of Thesys CAT LLC, the Plan Processor for the Consolidated Audit Trail (CAT). In this capacity, he is responsible for the leadership, management, operations, and strategic build out of the CAT system. Mr. Frank is responsible for ensuring the CAT NMS requirements are met for the Securities Exchange Commission (SEC) mandated big data analytics platform, including coordination with the SEC, Self Regulated Organizations (SRO) and the industry at large. In his role, he sets the vision for rest of the Thesys CAT management team including the technology, business management, operations, product development and project management teams. Additionally, he works closely with the Thesys CAT LLC Chief Compliance Officer to ensure full compliance with applicable rules and the Plan Processor Agreement, with the Thesys CAT LLC Chief Information Security Officer to ensure that all security requirements of the solution and data are met and the Thesys CAT LLC Chief Technology Officer for the build out and technology operation of the CAT. Prior to assuming the role as President of Thesys CAT LLC, Mr. Frank was Chief Operations Officer, of Thesys Technologies, LLC, a leading big data and market structure technology subsidiary of Thesys Group, Inc. (formerly Tradeworx). In this capacity, Mr. Frank was responsible for the Product and Service Organization. As a member of the Thesys executive leadership team, he managed the Company’s strategic product roadmap, technology development, operations and critical functions such as cyber- security and risk management, and served as an Advisory Committee Member for Thesys CAT LLC. He was instrumental in the build for Thesys’ financial big data business providing high performance technology to market participants, including institutional investors, traders, brokers, exchanges and regulatory agencies. He was responsible for securing the contract for the SEC’s Market Information Data Analytics System (MIDAS). Mr. Frank has over 20 years of experience in global capital markets and financial technology, managing successful business ventures while executing on large scale complex projects. He’s an expert in implementing technology leadership and productivity programs, with a strong focus on transformations. Mr. Frank has held leadership positions at organizations such as Citibank, Liquidnet, FXall, a Thomson Reuters company, and Deloitte and Touche. He successfully built and led high performing project teams in excess of 100 members to set up the E*​Trade Bank in Germany, delivering multi​-year programs of next generation systems in financial institutions, transforming multiple technology organizations to operate more efficiently. Mr. Frank holds a B.A. at the Technische Universitat Berlin in Economics. He is fluent in German and English.

Shane Swanson

Chief Compliance Officer, Thesys CAT LLC

Shane Swanson is currently Chief Compliance Officer of Thesys CAT LLC, the Plan Processor for the Consolidated Audit Trail (CAT), as well as Chief Compliance Officer for CAT NMS, LLC. In this capacity, he is responsible for ensuring the CAT system is built and operating in a compliant manner. He is also responsible for executing the CAT NMS requirements, including all compliance matters and operations surrounding market structure related to the platform. In his role, Mr. Swanson oversees the accuracy and reporting of the data, as well as the health of the system functionality of the CAT technology platform. Additionally, Mr. Swanson has fiduciary responsibility to CAT NMS, LLC. Mr. Swanson is an experienced financial services leader, General Counsel and Compliance Officer. He most recently served as Director of U.S. Market Structure at Citadel. Prior to that, he was at Citigroup Global Markets, Inc. as Managing Director and CEO of Automated Trading Desk Financial Services, LLC. Mr. Swanson was also Partner, General Counsel, and Chief Compliance Officer of Eladian Partners LP. Mr. Swanson holds a Juris Doctor from the University of South Carolina School of Law and a Baccalaureus Artium et Scientae from the University of South Carolina.

Vas Rajan

Chief Information Security Officer, Thesys CAT LLC

Vas Rajan is Chief Information Security Officer (CISO) of Thesys CAT, LLC, subsidiary of Thesys Technologies, LLC, a leading capital markets technology provider. Thesys CAT LLC is the Plan Processor for the Securities and Exchange Commission (SEC) mandated Consolidated Audit Trail (CAT) and is responsible for building and operating the world’s largest financial database. Mr. Rajan was selected as CISO by Thesys CAT and the Self Regulatory Organizations (SROs) that comprise the Operating Committee of CAT NMS, LLC. As CISO for Thesys CAT and CAT NMS LLC, he is responsible for all aspects of security of the data and systems of the CAT, as well as interfacing with the and SEC as regulatory users of the CAT. Additionally, Mr. Rajan has a fiduciary responsibility to CAT NMS, LLC. Prior to becoming CISO of Thesys CAT in 2018, Vas served as CISO for CLS Bank International, the member owned foreign exchange settlement service. As a Systemically Important Financial Market Utility (SIFMU), CLS was required to have a very rigorous security posture. Prior to CLS, Vas was Head of IT Security at ING Direct USA, and its subsidiary Sharebuilder.com. He has been a technologist in the financial services industry for over 20 years. Vas received his Bachelor’s Degree from Rutgers College, Rutgers University and earned his MBA from the Graduate School of Business at Columbia University.