July 22, 2019 Via Electronic Filing Mr. Paul Cellupica, Esquire Deputy Director and Chief Counsel Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Custody Rule and Trading Controls Relating to Bank Loans Dear Mr. Cellupica: The Loan Syndications and Trading Association (“LSTA”)1 appreciates the invitation from...