BDA submitted a comment letter in response to MSRB’s request for comment on draft MSRB Rule G-49 on minimum denominations. BDA Letter Summary: The letter states that the proposed MSRB Rule G-49 should be focused on issuances with ‘minimum authorized denominations’ of $100,000 and above Additionally, the letter argues that dealers should have increased flexibility to…
Author: Bond Dealers of America
BDA Submits Comment Letter to the SEC: MSRB Retail Confirmation Disclosure Rule Proposal
BDA submits comment letter to the SEC on the MSRB’s retail confirmation disclosure rule proposal and the proposed amendments for establishing ‘prevailing market price’. BDA has submitted a comment letter to the SEC in response to the MSRB’s filing of its proposed retail confirmation disclosure rule along with proposed guidance amendments to MSRB Rule G-30 related to…
BDA Submits Comment Letter on FINRA Gifts, Gratuities and Non-Cash Compensation Rules
BDA submitted its comment letter to FINRA in response to its request for comment on proposed amendments to its gifts, gratuities, and non-cash compensation rules. You can view FINRA’s regulatory notice here. FINRA has proposed to consolidate various interpretative guidance documents related to gifts and non-cash compensation into the FINRA rulebook. Additionally, FINRA is proposing to increase…
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BDA Submits Comment Letter to the SEC on FINRA’s Retail Confirmation Rule
Today, BDA submitted a comment letter to the SEC in response to FINRA’s proposed retail confirmation disclosure rule. BDA’s letter focuses on: The urgent need for FINRA and MSRB to harmonize their rules from a policy, testing date, and effective date standpoint BDA urges regulators to appreciate the operational burdens associates with automating the process for making…
BDA Submits Comment Letter to the SEC on FINRA's U.S. Treasury Transaction Reporting Proposed Rule
BDA submitted a comment letter to the SEC on FINRA’s proposed rule to require reporting of U.S. Treasury security transactions to TRACE. BDA’s comment letter expresses general support for the proposal. However, BDA urges regulators to not implement fees or pursue public dissemination of Treasury transaction information in the future. In addition, BDA urges FINRA…
BDA Submits Letter to the SEC on MSRB's RTRS Academic Data Set Proposal
Today, the BDA submitted its letter to the SEC on MSRB’s proposed rule to establish a new data set of RTRS transaction data exclusively for institutions of higher education. The comment period expires on August 10, 2016. You can view the BDA’s letter here. BDA’s letter opposes the creation of the new data set as…
BDA & Others CDA Letter
Today, BDA and other associations sent a letter to the SEC Office of Municipal Securities on amending issuer continuing disclosure agreements (CDAs). “In the Adopting Release for the 1994 Amendments to Rule 15c2-12, the Securities and Exchange Commission (“SEC”) promoted flexibility in drafting CDAs required by the amended Rule while adhering to a basic framework,…
BDA and Others Submit Comments to the SEC on CDAs
“In the Adopting Release for the 1994 Amendments to Rule 15c2-12, the Securities and Exchange Commission (“SEC”) promoted flexibility in drafting CDAs required by the amended Rule while adhering to a basic framework, in line with the official statement for the particular offering. As a result, there is no uniform CDA used by all over the…
BDA Submits Comment Letter to the SEC on FINRA's TRACE Academic Data Set Proposed Rule
BDA submitted a comment letter to the SEC on FINRA’s rule proposal to create a new TRACE data set for institutions of higher education. BDA’s letter opposes the creation of the new data set because it would create unnecessary business risks for broker-dealers. BDA requests that FINRA re-propose the rule proposal and have dealers grouped anonymously…