SIFMA provides comments to the Securities and Exchange Commission (SEC) on a proposed Financial Industry Regulatory Authority, Inc. (FINRA) rule change that would require members to report OTC equity transactions as soon as practicable, but no later than 10 seconds, following execution, File No. SR–FINRA–2013–013.  If approved,  FINRA would amend its trade reporting rules to require that members report over-the-counter (OTC) transactions in National Market System (NMS) stocks and OTC Equity Securities, and cancellations of such transactions, to FINRA as soon as practicable, but no later than 10 seconds following execution.  SIFMA believes the SEC should not approve the proposed rule change unless FINRA provides additional information, including an economic analysis, to justify the need for the proposal in light of the substantial systems changes that members would have to make to comply with the new reporting requirements.