SIFMA provides comments the Securities and Exchange Commission (SEC) on the Financial Industry Regulatory Authority’s (FINRA’s) Notice of Filing of Proposed Rule Change Relating to Post-Trade Transparency for Agency Pass-Through Mortgage-Backed Securities Traded in Specified Pool Transactions and SBA-Backed Asset-Backed Securities Transactions (Release No. 34-66804; File No. SR-FINRA-2012-021).

SIFMA discusses the potential for breaches of the confidentiality of member trading strategies and positions in the specified pool market, and make a modest proposal to ameliorate those concerns.

This letter was developed with SIFMA’s Dealer Agency MBS Trading Practices, Agency MBS Investor, and TRACE Implementation committees.