June 10, 2013
I support the proposed rules' requirement to submit trades without any pre-processing which could erode the accuracy and timeliness of submission of data on trades to the NSCC. Pre-processing including netting could eliminate identification of wash trades which might be designed to alter apparent volumes or prices of securities, or otherwise hinder the real time accurate recognition of trading volume or prices. Any cost associated with slightly higher volumes of data from limiting pre-netting is small compared to the risks and costs of inaccurate data which might result from submission of other than accurate trade data.