An Ad Hoc Committee of the Securities Industry Association (SIA) provides comments to the National Association of Securities Dealers, Inc. (NASD) and the NASD Regulation, Inc. on the Phase Three implementation of the NASD Order Audit Trail System (OATS).  SIA shares concerns about the timing of reporting an order. For purposes of an audit trail, SIA believes the more meaningful time is the time the order is entered into an electronic system for execution.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.