June 24, 2022

Secretary
Securities and Exchange Commission
100 F St. NE
Washington, D.C., 20549-1090

Re: FINRA’s Rule Proposal SR-FINRA-2022-013

SIFMA and its members appreciate the opportunity to respond to FINRA’s Rule Proposal SR-FINRA-2022-013, “Notice of Filing a Proposed Rule Change to Amend FINRA Rule 6730 to Enhance TRACE Reporting Obligations for US Treasury securities.”1 SIFMA would like to raise our concerns associated with both elements of the Rule Proposal – the proposed changes to the granularity and consistency of execution timestamps as well as the proposal for a reduction in reporting timeframes.

At a high level, we encourage FINRA to review the proposed 60-minute reporting time requirement within the broader context of policymaking in this area, and to hold off on any rule changes until after the upcoming broader analysis of the Treasury market and its reporting requirements has been conducted. Additionally, we believe the proposed change in execution timestamps presents a range of technical and operational challenges due to the range of platforms and venues used by firms which are engaged in Treasury market activities.

Reporting Time Frame Reduction

We understand and appreciate FINRA’s interest in shorter reporting timeframes, however we urge FINRA to be conscious of the broader policymaking environment associated with Treasury markets and their reporting requirements, and in light of the discussions and pending Treasury analysis underway on these issues, to hold off on rule changes on reporting timeframes at this time.

For example, the US Treasury has announced that, in consultation other members of the Inter-Agency Working Group on Treasury Market Surveillance (IAWG), it is exploring the possibility for greater transparency for secondary market transactions of Treasury securities. 2 The US Treasury also recently released a Request for Information (RFI) where a broad range of market actors will be called upon to provide feedback on additional post-trade transparency of data regarding secondary market transactions of Treasury securities.3 Similarly, SEC Chair Gensler in April 2022 discussed the prospects for reviewing changes to reporting time frameworks.