Anonymous Comment On Regulatory Notice 22-17
My firm is a 2 principal firm where I do institutional fixed income and my husband does retail. no assistants. I currently report to Trace myself vs. the clearing firm as my public agency clients purchase GSEs that are underwritten throughout the day vs. 1 time like munis and corporates. Only FHLMC and FNMA have P1 reporting on the 1st day, both FHLB and FFCB are S1 reporting. The clearing firm may not have the cusip set up, so if I enter through their system, I may get the "security not found" I it will be late in reporting since it will take them at least 20 minutes to get the cusip set up in the system. Many times, a municipality will come in and list 2-3 maturities to purchase. If they are treasuries or S1 reporting, I will not make the 1 minute deadline as I'll need time to manually enter 3 separate securities into TRACE within 1 minute. As a small firm, I can not afford the $200m+/year to have Bloomberg tickets filter through to the clearing firm; it is manual for me. Maybe 1 trade will make it, the other 2 will be late reporting. The client has given the order price, I execute dealer/dealer on their price and the order price is confirmed back to the client upon execution, so there is no room to wait and see about getting a better price, so I don't see the benefit to the client of 1 minute reporting. Who does that benefit? The client knows the execution price. This 1 minute reporting will only ensure that the small firm will be habitually late. This change assumes you are entering only 1 trade at a time, but clients can come back with multiple orders and 1 minute to report just won't cut it; 15 minutes is a fair time, although small firms that report to Trace manually are still scrambling. I've been in this business for almost 40 years and you'd think technology would benefit the small dealer, but it just gets more difficult and costly every year to make a living.