Jun. 12, 2024
I am opposed to an extension of delaying the implementation of SLATE. I disagree with SIFMA's comments that SLATE oversteps FINRA's data collection mandates from an inflexible and narrow reading of Rule 10c-1a under the Securities Exchange Act of 1934. The data elements to be collected were determined well before financial instruments and derivatives that obfuscate their disclosures were invented, and Rule 10c-1a does not suggest that the elements from (c) to (e) are exhaustive of what is necessary to secure transactional integrity. Additionally the SLATE proposal does not necessarily need to go through the cost-benefit analysis SIFMA is suggesting. Much like infrastructure spending, a cost benefit analysis should be done with market stability and resilience in mind (and associated loss/harm from a market event that would not be resolvable without the elements SLATE would collect), and not from a purely monetary aspect. This is also a matter of data collection and record-keeping, and NOT an impact to the primary activities of market making and clearing, and as such it would be further inappropriate to conflate this as needing the same rigorous scrutiny as an operational change.