BDA has submitted its comment letter to SEC on FINRA Rule 4210, to establish margin requirements for the TBA Market. The BDA’s letter can be read here. BDA’s comment letter highlights that the burden of this rule will fall on small-to-medium sized dealers transacting with medium-to-large sized counterparties and focuses on the following areas of…
Author: Bond Dealers of America
Bond Dealers of America Announces Hiring of Federal Policy Advisor
October 29, 2015 – Washington, D.C. – The Bond Dealers of America is pleased to announce the hiring of Justin Underwood to serve as Federal Policy Advisor, an internal staff position at the BDA. Justin comes to the BDA from FINRA where he served as Regulatory Analyst – Market Regulation, Trading Analysis. Click here to…
2015 BDA Fixed-Income Compensation Survey
As the only organization representing the unique interests of securities dealers and banks focused primarily on the U.S. fixed income markets, the Bond Dealers of America (BDA) is pleased to present the results of the Seventh Annual Fixed-Income Dealer Compensation Survey. To download the complete report, please click here.
BDA Submits Issue Price Comment Letter to IRS
Today, BDA submitted a comment letter to IRS in response to its request for comment on a proposed rule to re-define ‘issue price’. The proposal partially withdraws the 2013 issue price proposal. The BDA’s draft letter focuses on: Problems for issuers and the marketplace that will be caused by an actual sales approach and the absence of a…
BDA Submits Letter to SEC on MSRB Proposed Rule G-42 Regarding the Core Duties of Municipal Advisors
In its letter to the SEC, BDA reiterates our concern with the Proposed Rule’s absolute ban of related principal transactions and urges the Commission to disapprove the Proposed Rule so that the MSRB can redesign a more reasonable conflicts of interest regime. Specifically, the BDA believes: The proposal that certain principal transactions be banned is out…
BDA Sumbits Letter to SEC on TRACE 'No Remuneration' Indicator
BDA submitted a letter to the SEC in response to a request for comment on a proposal to require a ‘No Remuneration’ indicator for TRACE trade reports when trade prices do not include a commission or markup, markdown. This SEC-filed proposal would harmonize TRACE reporting with the previously approved amendments to G-14 for municipal securities trade reporting. The…
BDA Submits Comment Letters to FINRA and MSRB on Market Data Sets
BDA submitted the two letters in response to two requests for comment by FINRA and one request for comment by the MSRB. Both FINRA and MSRB requested comment on a new academic data set that would include a dealer-specific identifier. The second, FINRA specific, request for comment is a proposal to reduce the delay associated…
NABL Releases Paper on Disclosure Policies and Procedures
NABL has released a paper entitled Crafting Disclosure Policies, to provide NABL members with tools to advise issuers in developing written disclosure policies and procedures. The paper contains the following: An exploration of the functions and benefits (as well as risks) of written disclosure policies, the subjects that drafters should consider addressing, and practical considerations for drafting…
BDA Testifies Before U.S. Department of Labor on Fiduciary Duty
In his remarks, Nicholas focused on how the proposed expansion would significantly limit the ability of dealers to provide investment advice and recommendations to retirement investors. You can find his prepared remarks here. Specifically, Nicholas spoke about how the BDA does not believe the proposed rule or the associated exemptions represent the right approach for improving…
BDA Submits Comment Letter to SEC on Proposed Amendments to FINRA Rule 6730 to Require Members to Report Transactions in TRACE-eligible Securities 'As Soon As Practicable'
Today, BDA submitted a comment letter to the Securities and Exchange Commission on a proposal to codify in FINRA Rule 6730 that members are expected to report transactions in TRACE eligible securities that are subject to dissemination “as soon as practicable” (but not later than 15 minutes of the time of execution or other timeframe…