Subject: cll-13: WebForm Comments from Alan Reid
From: Alan Reid
Affiliation: Over 30 years in financial services, C level exec, served on The ICI Board, as well as a post 2008 working group at The Fed

Sep. 29, 2022

September 29, 2022

 While I have been happy to see a much more fluid  list of engagements and public communication of issues, this proposal falls short in one obvious area: cooperation and constructive engagement with industry.

Over the past thirty years I have watched commission after commission get left behind, struggling to keep up with the pace of change.  This is not surprising as public service does not always offer considerable appeal over the larger salaries private companies may offer.

I have spent the past twenty years bringing topics to the SEC, with slow response times at best. Once it was the insistence by the SEC that mutual fund market timing hadn't hurt anyone.  That was the mandate until I went to the press and then NY State began actions.  I shared recommendations on liquidity that appeared verbatim 7 years later in the commission policy on liquidity for money markets.  And yes, the list goes on.

Industry has a vested interest in markets stability and validity.  We arguably more focused on long-term, as for our clients and our firms that can be in excess of 30 years - 10x the life of the average SEC Chair.