Subject: SR-FINRA-2024-007
From: Richard Hu
Affiliation:

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.