NYSE Euronext Comment on Notice 07-46

November 6, 2007 Sent via pubcom@finra.org Barbara Z. Sweeney Office of the Corporate Secretary FINRA 1735 K Street, NW Washington, DC 20006-1506 Re: Request for Comments on Proposed Amendments to OTC Trade Reporting Requirements for Equity Securities Dear Ms. Sweeney: Archipelago Trading Services, Inc. (“ArcaEdge”) appreciates the opportunity to comment on the Financial Industry Regulatory Authority’s (“FINRA’s”) proposal to amend the reporting requirements for over-the-counter transactions of listed and unlisted equity securities (“OTC Securities”). We believe the current trade reporting hierarchy leads to unintentional confusion by and between market participants, placing unnecessary burdens, both from a regulatory and financial point of view, on the member firms. ArcaEdge strongly supports FINRA’s efforts to continue to improve upon the mechanisms of the OTC Securities market, and its proposal to create a more efficient means to report such transactions. Therefore, as described more fully below, ArcaEdge supports FINRA’s proposal that the sell-side to each transaction be required to report each trade, except where such trade is with a customer or non-member firm. Executive Summary FINRA Rule 6000 et seq. stipulates the hierarchy by which member organizations must coordinate to report transaction of OTC Securities. Terms such as “Reporting ECN” and “Reporting Market Maker” are defined for use within a complex ...