Today, BDA submitted a comment letter to FINRA in response to its request for comment on a proposal to expand dissemination of TRACE data to include an additional group of securitized products. The BDA’s letter can be accessed here. Proposal Executive Summary: FINRA is soliciting comment on a proposal to expand dissemination of TRACE data to include “additional Securitized…
Author: Bond Dealers of America
BDA Announces New Due Diligence Webinar Training Series for Municipal Market Bankers
The Bond Dealers of America and Nixon Peabody have announced a new series of training webinars–exclusive to BDA member firms–focused on providing specialized due diligence training to public finance bankers. This series will be led by BDA retained counsel, Nixon Peabody and feature commentary and analysis from BDA member firm counsel and public finance bankers.…
BDA Announces FY 2015 Board and Board Leadership
The BDA membership has approved five new directors for the BDA Board: Tom Dannenberg, Hutchinson, Shockey, Erley & Co.; Angelique David, Ziegler; Keith Kolb, Robert W. Baird; John Rolander, Fifth Third Securities; and Don Winton, Crews & Associates, Inc. In addition, at the BDA’s fourth quarter Board meeting on February 5, the Board approved FY…
BDA Letter to Editor Published in Wall Street Journal: Highlights the Impact of Federal Regulatory Burden on U.S. Securities Firms
The purpose of BDA’s letter is to highlight – as Mr. Blankfein fully recognizes – the outsized impact of the current regulatory environment on all U.S. based securities firms, but especially those smaller firms less able to weather dramatic increases in compliance costs. BDA argues, the aggregate impact of the current regulatory environment harms the ability of smaller…
BDA Submits Comment Letters: FINRA and MSRB Proposed Pricing Reference Disclosure Rules
BDA submitted an identical comment letter to both FINRA and MSRB in response to their request for comment on a proposed rule to require a pricing reference disclosure on certain retail-size fixed income trades. The BDA’s letter can be accessed here. The BDA’s letter focuses on several core issues with the proposed rule. Regulators have yet to explore…
BDA Submits Comment Letter: SEC Rule 15c2-12
BDA submitted a comment letter to the SEC regarding its request for comment on SEC Rule 15c2-12. The BDA’s letter is accessible here. The Commission solicited comments on the regulatory burden for underwriters and issuers associated with Rule 15c2-12 compliance. In addition, SEC requests comments on “ways to enhance the quality, utility, and clarity” of information collected…
2014 Year in Review – BDA Federal Advocacy
Regulations & Securities Law FINRA Margin Amendments In January, FINRA published a request for comment on proposed amendments to Rule 4210—margin rules for the TBA market. The proposed amendments would require the collection of margin for exposures greater than $250,000 on a variety of transactions on which there is currently no margin requirement. In March,…
The Bond Buyer Publishes BDA Op-Ed: Clearing Up the Confusion on Non-Dealer MA Registration
This week The Bond Buyer features an op-ed by the BDA entitled, “Clearing Up the Confusion on Non-Dealer MA Registration.” The commentary is in response to an article in The Bond Buyer on December 16 on a letter from the National Association of Municipal Advisors to the SEC requesting “exemptions from broker-dealer and investment adviser…
BDA Submits Comment Letter: MSRB Proposed Amendments to Extend Rule G-20 Provisions on Gifts, Gratuities and Non-Cash Compensation to Municipal Advisors
The request for comment is available here. You can find BDA’s final letter here. The MSRB’s proposed amendments would: Apply Rule G-20 to all municipal advisors, prohibiting gifts or gratuities in excess of $100 per person per year in relation to the municipal securities activities of the recipient’s employer Apply the related record-keeping requirements of MSRB…
BDA Submits Comment Letter: FINRA Proposed Rule to Implement Comprehensive Automated Risk Data System (CARDS)
The BDA submitted a comment letter to FINRA in response to its request for comment on a proposed rule to establish the Comprehensive Automated Risk Data System (CARDS). You can find the BDA’s final letter here. CARDS would require broker-dealers to submit to FINRA comprehensive customer account and transaction data for each of its customer accounts on…