BDA today filed comments with the MSRB and FINRA on their coordinated proposals to reduce the time dealers have to report trades to the MSRB’s Real-time Trade Reporting System (RTRS) and FINRA’s Trade Reporting and Compliance Engine (TRACE) from 15 minutes to one minute (MSRB proposal and FINRA proposal). We told the agencies “BDA strongly opposes the Proposals and we urge the MSRB and FINRA to abandon these initiatives and continue to allow the industry to improve reporting times organically.”
BDA also told the regulatory agencies “If it was possible for dealers to report 100 percent of trades within one minute, they would already be adhering to that standard since the Rules explicitly or effectively require reporting as soon as practicable. If dealers are already reporting trades as fast as they can, it is unreasonable to impose a one-minute requirement they cannot always meet.”
Our letter also focused on the effects of the proposals on small dealers, among other issues, citing comments in the MSRB proposal that one-minute reporting could drive some firms out of the secondary trading business. “Regulating firms out of business would be an unacceptable outcome of the Proposals. Any marginal benefits associated with faster trade reporting would be undercut by negative outcomes for small firms and their customers,” we wrote.
BDA’s letter is available here. As always, please call or write if you have any questions.