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Colliers Securities LLC Comment On Regulatory Notice 22-17

Thomas Steichen

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. I am writing you this letter relating to The Municipal Securities Rulemaking Board (the “MSRB”) proposal Notice 20220007 “Request for Common on Transaction Reporting Obligations under MSRB Rule G-14” and the FINRA proposal Regulatory Notice 22-17 “FINRA Requests Comments on a Proposal to Shorten the Trade Reporting Timeframe for Transactions in Certain TRACE-Eligible Securities from 15 Minutes to One Minute.” Colliers Securities strongly agrees with the letter dated October 3, 2022 that was sent to you by the Bond Dealers of America. Reducing the mandated reporting time frame from 15 minutes to one minute would be overly burdensome for dealers, especially smaller dealers such as ourselves, to comply with. We feel that it is unreasonable to impose a one-minute requirement on dealers that they cannot always meet for a variety of reasons. We believe such one-minute requirement would put undue pressure and added expenses on small firms and would be damaging and unnecessary to such small firms in that it would involve substantial costs relating to technology and a change in the business without any measurable benefits. Colliers Securities strongly opposes the proposals to require a one-minute requirement on trade reporting and we urge the MSRB and FINRA to abandon these initiatives. Let me know if you have any questions regarding this matter. I can be reached directly at (612) 376-4060. Thank you, Thomas Steichen General Counsel