In a comment letter, SIFMA supported the concept of a FINRA-proposed pilot program for delaying trade reporting of block trades in corporate bonds. The pilot program is intended to improve the willingness of dealers to take on large positions. However, SIFMA said, the proposal was "far too complex." SIFMA requested, among other changes to the pilot program, that block size be defined as $3 million for non-investment grade corporate bonds, rather than $5 million under FINRA's proposal.

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