In reading about the recent filing by the Municipal Securities Rulemaking Board with the SEC to amend MSRB rule G-14 to shorten the timeframe for trade reporting from the current 15-minute standard to as soon as practicable, but no later than one minute after the time of trade, I honestly have to question what sort of benefit this almost-immediate reporting delivers or if this rule may very well adversely impact certain types of liquidity. With over thirty years in the fixed income markets including bond sales and extensive experience in electronic trading, I deeply understand the value of delivering expedient and efficient pricing and transaction data to the broader markets. However, I think it is very important to examine the categories of beneficiaries from these proposed material increases in transparency. I wouldn't guess that the the large asset manager, pension fund, bank portfolio or even bank liquidity providers executing hundreds or thousands of trades per day requires or more importantly, benefits from sub-60 second reporting transparency for the following reasons that I acknowledge are basic and well-known, but allow me to put some ideas into perspective. A significant function of market making and liquidity provision relies on the orderly transfer of risk from the buyside to the sellside. In some instances, clients are buying from existing dealer or market maker liquidity but in many instances, it's the market makers or liquidity providers ((LP) who are buying inventory from clients. This is where the time-critical risk transfer and all associated hedging not only becomes an essential part of the transaction, but is incremental in the ability of the LP to provide the bid in the first instance. Many trading desks, in their ongoing effort to win client business and grow their franchise, engage in fierce competition with traditional and quantitative algorithmic liquidity providers. When a trading desk executes a large client trade, it isn't uncommon for a sales desk to wait or was even informed of the trade UNTIL a reasonable degree of risk managed hedging had occurred to allow the trader to show out all or a portion of that trade or axe. For al of the gains that have been made with electronic trading and the consumption of data, many of these very fundamental tenets of liquidity and risk transfer remain today. As the role of data has become increasingly critical for accurate and timely market making, the breadth of data quantitative traders consume spans traditional pricing data to credit card transaction, weather, shipping cargo traffic, web scraping and so on. The world has clearly gotten far more sophisticated and the role of data science is only just beginning in many ways. While quantitative traders get far more sophisticated, it is critically important to acknowledge that many if not most of the quant traders are not nearly the same firms dedicating balance sheet and engaging in the orderly process of liquidity provision and risk transfer for the clients that broadly occupy the real money definition. From my experience working in electronic trading and market making, it was always the quant or principal trading firms that were faster and more efficient in reacting to every move in the market as they had the fastest connections and the most sophisticated algorithms to capture incremental movement or spreads. While many of the largest banks have entered this era of sophistication, there remains one very significant difference between these two categories of firms that is, balance sheet. Quant firms don't have the ability or need to commit significant capital and broadly go home flat as capital charges would compromise many of their trading strategies. In moving to sub 60 second reporting, it's relatively clear to me that quant firms would greatly benefit from this time-critical information as the reporting of a large moderately-liquid investment grade, high yield or municipal trade often reprices that specific bond but also reprices the issuer and in some instances, the sector itself. If our markets continue to move to a place where LPs become less willing to engage in aggressive, on-the-market risk transfer, then clients and the orderly liquidity of the markets become the biggest losers as spreads will surely widen and more algo-driven price reaction will benefit this single facet of the markets. And while this proposed rule change does include accepted delays for manual trades, this amendment will serve to prevent the progression of larger negotiated trades moving to electronic channels. To put this into context, no matter how much the power of AI and algo driven trading advances, there will remain these very basic core principals in the way D2C trading occurs where clients speak to salespeople or execute on a platform and trades often include or require a degree of risk transfer and associated hedging. If regulation, in its often misguided goal to be more transparent for the mom and pops of the world, continues to move in the direction of nearly immediate trade reporting, I submit that the benefits will be negligible and the net effect to liquidity will likely be quite the opposite of what is intended. Thank you, Michael