SIFMA provides comment to the U.S. Securities and Exchange Commission (SEC) on a proposed rule change to expand FINRA’s Alternative Trading System (ATS) transparency initiative. Under the proposal, FINRA would publish the equity volume executed over-the-counter (OTC), including that from non-ATS electronic trading systems and internalized trades. SIFMA generally supports the proposal, however, the aggregation and publication timeframes must be modified in order to minimize information leakage.