March 31, 2023

By Electronic Submission

Vanessa Countryman Secretary
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington DC 20549

Re: File No. S7-29-22; Release No. 34-96493; Disclosure of Order Execution Information (“Rule 605 Proposal”
File No. S7-30-22; Release No. 34-96494; Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders (“Tick Size Proposal”)
File No. S7-32-22; Release No. 34-96496; Regulation Best Execution (“Reg Best Ex”)
File No. S7-31-22; Release No. 34-96495; Order Competition Rule (“OCR”)

Dear Ms. Countryman:

The Securities Industry and Financial Markets Association (“SIFMA”)1 respectfully submits the following comments on the Rule 605 Proposal, the Tick Size Proposal, Reg Best Ex, and the OCR (the “Proposals”) by the U.S. Securities and Exchange Commission (“Commission” or “SEC”).2 SIFMA notes that it is submitting two additional letters related to certain of the Proposals3 and previously submitted a letter on February 8, 2023 requesting an extension of the comment period as well as requesting that the Commission provide the Consolidated Audit Trail (“CAT”) data used to support the Proposals to facilitate meaningful public comment on the Proposals, to which the Commission has not yet responded.4 SIFMA reiterates its request for these data and an extension of the comment period given the length, complexity and intersections of the Proposals.

 

1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s one million employees, we advocate on legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org.

2 Exchange Act Release No. 96496, 88 FR 5440 (Jan. 27, 2023) (Reg Best Ex); Exchange Act Release No. 96495, 88 FR 128 (Jan. 3, 2023) (OCR); Exchange Act Release No. 96494, 87 FR 80266 (Dec. 29, 2022) (Tick Size Proposal); Exchange Act Release No. 96493, 88 FR 3786 (Jan. 20, 2023) (Rule 605 Proposal).

3 Specifically, a working group of SIFMA members active in fixed income securities has submitted a letter addressing particular concerns of the application of Reg Best Ex to fixed income trading, and the Asset Management Group of SIFMA has also submitted a letter addressing concerns raised by the Proposals from an asset management perspective.

4 Letter from Ellen Greene, Managing Director, SIFMA, to Vanessa Countryman, Secretary, Commission (Feb. 8, 2023), https://www.sec.gov/comments/s7-31-22/s73122-20156863-325026.pdf (“SIFMA Letter I”).