BDA submitted the two letters in response to two requests for comment by FINRA and one request for comment by the MSRB. Both FINRA and MSRB requested comment on a new academic data set that would include a dealer-specific identifier. The second, FINRA specific, request for comment is a proposal to reduce the delay associated with historical TRACE data from 18 months to 6 months.
BDA’s letter to FINRA (available here) addresses both topics described above and expands on the following:
- With regard to the historic TRACE data, we express support for the reduced delay associated with the historic TRACE data, which does not include a dealer-specific identifier.
- With regard to the new academic data set, we express opposition to the new academic data set because it would include a dealer specific identifier, which creates an unnecessary risk for dealers with regards to the potential for reverse engineering a dealer identity.
- BDA’s letter to the MSRB (available here) also expresses opposition to the academic data set proposal.
- FINRA’s academic data set notice can be read here and the historic data set request can be found here.
- MSRB’s academic data set request can be read here.
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