December 21, 2000
Jonathan G. Katz, Secretary
Securities & Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609
Re: File No. SR-NASD-99-65, Amendments 2 & 3 (NASD Corporate Bond Trade Reporting Facility)
Dear Mr. Katz:
The T+1 Streetside Fixed Income Working Group ("the group") is writing in support of the comment letter filed by the Securities Industry Association (see attached) in response to the above referenced rule filing.
The T+1 Streetside Fixed Income Working Group is a sub-group of the SIA T+1 Streetside Committee. Working with the Bond Market Association, the group is focused on addressing issues relating to comparison, netting and settlement issues in anticipation of shortened settlement cycles in the fixed income securities market.
The group shares the concerns regarding bifurcated systems efforts, submission of clearance information and optional comparison discussed in the SIA letter. Moreover, we endorse the letter's ultimate recommendation that NASD ought to work to ensure that its trade reporting function works within the context of ongoing industry effort to consolidate and expedite all post-trade processing functions across all fixed income markets. T+1 is a vitally important project for reducing risk in the financial markets. Achieving the goals of T+1 will require the unprecedented cooperative efforts on the part of broker-dealers, markets and utilities. As the industry migrates toward consolidated data flows and post-trade processing functions to achieve this goal, it is essential that any entity, such as TRACE, that is seeking to offer a post-trade function, such as reporting, also cooperate with the existing industry-wide effort.
The group supports the goal of fixed income transparency for corporate bonds and looks forward to working with the NASD. The industry's preferred model will benefit transparency by providing more accurate information and on a timelier basis.
If we can provide any further information or clarification of the points made in this letter, please contact the undersigned at (201) 524-4800.
Very truly yours,
Eleanor Davis Ainspan, Chairperson
T+1 Streetside Fixed Income Working Group
cc: Honorable Arthur Levitt, SEC
Honorable Isaac C. Hunt, Jr. , SEC
Honorable Laura S. Unger, SEC
Honorable Paul R. Carey, SEC
Annette Nazareth, Director, Division of Market Regulation, SEC
Robert L.D. Colby, Deputy Director, Market Regulation, SEC
Belinda Blaine, Associate Director, Market Regulation, SEC
Stephen L. Williams, Special Adviser to the Director, Market Regulation
Alden S. Adkins, General Counsel, NASDR
Justin Tubiolo, NASDR
Jerome Clair, Chairperson, SIA Operations Committee
Art Thomas, Chairman, SIA T+1 Steering Committee