Comments on Proposed Rule on Consolidated Audit Trail, August 10, 2010

The following public comment was provided to the SEC on their proposed rule that would “require national securities exchanges and national securities associations (“self-regulatory organizations” or “SROs”) to act jointly in developing a national market system (“NMS”) plan to develop, implement, and maintain a consolidated order tracking system, or consolidated audit trail, with respect to the trading of NMS securities.”

Subject: File No. S7-11-10
From: Michael Erlanger
Affiliation: Managing Principal, Marketcore, Inc.

August 10, 2010

Sirs —

We suggest that this file be expanded to look at the creation of the instruments that underly the securities that make up MBS and ABS — and their actual performance across their full life cycle, inclusive of information captured at every intermediation.

If you think of it, only such a process could have predetermined that this current crisis would have started through excesses occurring in product creation and their aggregation for loans and lines of credit.

We have previously discussed this matter with the SEC’s Jonathan Sokobin and a wider range of individuals at Treasury Department and other senior regulators. As we consider the implications of data capture for protection against systemic risk, it should be a requisite.

Our work in this area has captured the interest of a large group of regulators, legislators and was a part of a CRS Report for Congress.

Sincerely Yours,

Michael Erlanger
Managing Principal
Marketcore, Inc

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