Subject: File No. SR-FINRA-2009-065
From: John Higum
Affiliation: Alexandria Capital Management Inc.

November 17, 2009

Ref: SR-FINRA-2009-065

To Whom It May Concern,

The addition of ABS to the TRACE system is a positive development. There is a question regarding the usefulness of the resulting data under the format that FINRA proposes.

As described in Rule 6730(a)(6), if the trade data is reported at the end of day or possibly the following week (if the trade takes place on a Friday) then it has little meaning in the context of the liquid markets. The trade information needs to be submitted simultaneously with their benchmarks in order for it to make sense.


John Hogue
Associate Portfolio Manager
Alexandria Capital Management Inc.