Submitted electronically to: [email protected]

Jennifer Piorko Mitchell
Office of the Corporate Secretary
FINRA
1735 K Street, NW
Washington, DC 20006-1506

RE: Regulatory Notice 22-26 – FINRA Requests Comment on Proposed Changes to TRACE
Reporting Relating to Delayed Treasury Spot Trades

Ms. Mitchell:

SIFMA and SIFMA’s Asset Management Group2 (“SIFMA AMG) are pleased to jointly submit these comments on Regulatory Notice 22-26 (the “2022 RN”), which expands on the prior
delayed spot trade reporting proposal3 by requiring the reporting of additional information for each trade in two separate linked reports, as follows:

At the time of spread agreement (w/in 15 minutes):

• Spread
• Associated benchmark CUSIP
• Other terms of the trade required by TRACE except dollar price

1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s one million employees, we advocate on legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).

2 SIFMA AMG brings the asset management community together to provide views on U.S. and global policy and to create industry best practices. SIFMA AMG’s members represent U.S. and global asset management firms whose combined assets under management exceed $45 trillion. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds.

3 See FINRA RN 20-24 (July 16, 2020), available here: https://www.finra.org/rules-guidance/notices/20-24, and SR-FINRA-2021-030, available
here: https://www.finra.org/rules-guidance/rule-filings/sr-finra-2021-030.