comment Letter on SR-FINRA-2007-012

FINANCIAL INFORMATION FORUM 5 Hanover Square New York, New York 10004 ⎯⎯⎯⎯⎯ 212-422-8568 February 29, 2008 Nancy M. Morris Secretary, Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090 Re: Securities Exchange Act Release No. 34-57020 (File No. SR-FINRA-2007-12); Proposal to Amend Trade Reporting Rules to Require Related Market Center Indicator on Certain Non-Tape Reports Submitted to FINRA Dear Ms. Morris: 1The Financial Information Forum (FIF) welcomes the opportunity to comment on the proposed changes to the Financial Industry Regulatory Authority, Inc. (“FINRA”) trade reporting rules. This filing notes FINRA’s belief “that the proposed rule change will promote a more complete and accurate audit trail,” and that “the proposed rule change will help ensure that members are not using non-tape reports to circumvent FINRA or Commission rules (e.g., trade-through rules).” The FIF Front Office Committee has reviewed FINRA-2007-012 and believes that including trade reporting venue on non-tape reports will increase the cost and complexity of trade reporting without realizing the intended benefits of a more complete audit trail and may not assist in ensuring that members are not improperly using non-tape reports to circumvent rules and regulations. Riskless principal trades often involve executions and reports on multiple markets. In such transactions, firms accumulate a position through multiple street-side ...