The Order Audit Trail System (OATS) Ad Hoc Committee of the Securities Industry Association (SIA)* provides comments to the Securities and Exchange Commission (SEC) on the National Association of Securities Dealers, Inc. (NASD’s) proposed rule change relating to an order audit trail system, SR-NASD-97-56.  SIA believes the August 1998 implementation date for the first phase is too ambitious given the extensive systems modifications that will be required.

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