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Eduardo Tovar Comment On Regulatory Notice 22-17

Eduardo Tovar

The 1 minute rule proposed would be very difficult for small broker dealers to keep, and would represent a major hurdle to our fixed income business. Most small broker dealers as is our case do not have a dedicate trading desk to handle this proposed new 1 minute rule, nor do they have the state of the art software that big firms may have access to. While compliance may be possible, this would likely dramatically increase errors and result in a worse execution outcome between counterparties. The emphasis on timing over quality and accuracy would harm the harmonious market this rule is intending to promote. This rule may be easy for large entities to comply with, but a healthy marketplace requires small players as well and this stacks the playing field against small firms. We have been in the fixed income business for decades, and strongly oppose this rule.