Proposal to Amend Trade Reporting Structure and Require Submission of Non-Tape Reports

SIFMA provides comments to the Securities and Exchange Commission (SEC) on a proposal by the Financial Industry Regulatory Authority (FINRA) to amend trade reporting structure and require submission of non-tape reports to identify other members for agency and riskless principal transactions, SR-FINRA-2008-011.  The FINRA proposal would amend the trade reporting rules for over-the-counter (OTC) equity securities and require the submission of non-tape reports related to certain riskless principal and agency transactions. SIFMA supports the simplicity of the new OTC Reporting Proposal, but believes some clarifications are necessary.  SIFMA requests that the SEC and FINRA defer consideration and approval of these amendments in order to collaborate more with other self-regulatory organizations (SROs) and the New York Stock Exchange (NYSE) on the rules.