Subject: File No. SR-MSRB-2024-01
From: J D Colwell

To the Commission, you may see a full letter of my opposing comments from September 2023 as submitted to the MSRB during their initial comment period in their recent filing to the SEC SR-MSRB 2024-01 dated January 12, 2024. A full listing of those comments along with 52 other submitter comments begin on page 223 of that 411 page document. Let me save you a little time – well over 90% of the commentors were opposed to the rule changes, albeit for various reasons. I see little sense in resubmission of those comments at this point other than to call this to your attention, as to me, it seems the Commission had their minds made up to go forward with these changes despite so many comments to the negative by such a diverse group of both large and small firms. Accordingly, we now see MSRB needing to compile a laundry list of exemptions to the one minute reporting within that filing in order to make it somewhat palatable to their "smaller" constituents and to at least facilitate some semblance of business as usual for a while. If you are now soliciting new comments, might I lead you to reviewing the ones that were already received and memorialized as a part of SR-MSRB 2024-01? While some of the exemptions listed under the proposed “Dealers with Limited Trading Activity (page 12) and “Exception for Trades with a Manual Component (beginning on page 15) may allay concerns for certain firms, it does not address one of the larger underlying problems – that of less competition. Suffice to say that the rule changes as promulgated by the Commission will end up doing more harm than good to the individual investors that you claim to protect. It will cause a further decline in the number of firms choosing to do business in the fixed income community due to increased costs and increased compliance burdens - which will lead to less competition. The smaller firms that actually help provide more liquidity in the marketplace do not have the extra quarter million dollars to install the systems that will be needed to continue to “play the game” as you now envision. Where individual customers may have received more than 5 bids, they now may receive two. Does the Commission believe this would help the small investor? Less competition does not mean better, more informed and knowledgeable bids with smaller spreads. At some point you end up with a smaller group of businesses controlling the pricing (see the FDA for an example of how well that works for the consumer). Or you can pick your own favorite firms and require that all transactions be executed on an automated transaction system and then you have the Bond Exchange some have always envisioned. To me, hiding this all under the disguise of "transparency" is no less egregious than calling a huge spending bill a "savings plan". In conclusion, show me the real market benefits of this proposal as compared to the almost predictable contraction in market knowledge, liquidity, and competition. Convince us that 14 minute faster trade reporting on a $ 10,000 trade in an issue of $ 1,500,000 total is going to make a legitimate difference to an average 12.8 BILLION (daily average for 2024 per MSRB statistics) marketplace. Thank you.