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Carlos Barrientos Comment On Regulatory Notice 22-17

Carlos Barrientos

I think that the proposed reduction to one minute reporting other than help investor protection will create a lot of problems for member firms, specially small firms. I think (and I am sure will happen more with small firms) that the number of errors in ticket generation will increase tremendously. This will then create delays in matching and settling trades (in addition to TRACE violations for not matching or reporting on time). This will also have a monetary impact (again, more in small firms) because of the need to "automate" as much as possible their systems. I have been speaking to FINRA staff regarding TRACE for many years now mainly about reporting New Issues of corporate bonds. I understand FINRA views and approach, but market convention is totally different. In summary, I think that this proposal to reduce TRACE reporting to one minute, will create more problems (regarding TRACE) than the ones there are currently. It will worsen the reporting situation for firms, resulting in higher TRACE violations (and maybe sanctions) to firms than the ones you currently see. Thank you for your attention.