It is Beech Hill Securities (BHS) opinion, that FINRA’s proposal to amend Rule 6730 to reduce TRACE reporting timelines to 1-minute will adversely affect the ability of small to mid-sized firms to participate in Fixed Income reportable securities. Given it is cost prohibitive, most small to mid-size firms do not utilize automated trade reporting systems (E.g., Bloomberg TOMS).

October 3, 2022 Ronald W. Smith Jennifer Piorko Mitchell Corporate Secretary Office of the Corporate Secretary Municipal Securities Rulemaking Board FINRA 1300 I Street NW 1735 K Street NW Washington, DC 20005 Washington, DC 20006-1506 Dear Mr. Smith and Ms. Mitchell: I am the General Counsel of Colliers Securities LLC.

October 3, 2022 Re: Regulatory Notice 22-17, Request for Comment on a Proposal to Shorten the Trade Reporting Timeframe for Transactions in Certain TRACE-Eligible Securities From 15 Minutes to One Minute Dear FINRA, In response to the proposed amendment to FINRA Rule 6730, we are respectfully providing comments as to why the amendment, which would change the reporting time from 15 minutes to one minute, in certain TRACE-eligible securities, is not a good idea, not practical, and will have adverse and discriminatory impacts to smaller sized firms and their customers.