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Michael Moise Comment On Regulatory Notice 22-17

Michael Moise

This proposal will blatantly continue to negatively impact small member firms that do not have neither the current infrastructure, capital or staffing levels to accommodate this significant of a change to their reporting structure. The continued demise in the number of FINRA-registered small firms, which benefits the largest firms with additional greater market share, provides the cover for the statistics used to consider this change. The statistic that 80+% of trades are reported within 1 minute should be cross referenced by which firm type is doing the reporting to get a true gauge on who will really be impacted. This decision, if enacted, will certainly cause the closure of additional small firms that can no longer compete with the largest of firms, continuing a trend that has never been fully addressed over the past 10 years as FINRA continues to enact rules that only benefit its largest constituents. FINRA should spend more time defending its small firms and ensuring a competitive industry for the benefit of the investors that FINRA has vowed to protect.