Today, 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…
Author: Bond Dealers of America
BDA Sends Letter to SEC on SMMP Exceptions, Requests Bifurcated Affirmation Process
This letter focuses on the SMMP exemption and its relation to the best execution rule. Currently, the proposed rule provides for one affirmation which allows a market participant to declare itself an SMMP or not. In the proposed rule, a market participant that declares itself an SMMP would effectively exclude its transactions from the protections…
BDA Sends Letter to SEC & MSRB: Urges Closer Look at Non-Dealer Placement Activities
The BDA sent two identical letters to the SEC and MSRB, focusing on the rapid growth of “direct placement, direct loan or private placement” transactions to banks and other investors. In its letter, the BDA states, “Now that the SEC is enforcing its own, and the MSRB’s regulations in regards to non-broker dealer municipal advisors we…
BDA Submits Comment Letter – MSRB 2015 Strategic Priorities
BDA’s letter focuses on: Municipal Advisor Regulation and Education Municipal Entity Protection Price Transparency MSRB Rule Language and Objectivity Cost-Benefit Analysis Should be More Rigorous and Education, Outreach and Market Leadership You can find BDA’s final comment letter here.
BDA Member Profiles
To view BMO Harris Bank, N.A.’s member profile click here. To view BondWave, LLC’s member profile click here. To view MarketAxess’ member profile, click here. To view Verus Consulting’s member profile, click here. To view Investortool’s member profile, click here. To view Lumesis’ member profile, click here.
BDA Submits Comment Letter to MSRB on Rule G-37
Today, the BDA submitted a comment letter to the MSRB in response to a request for comment on draft amendments to Rule G-37 on political contributions made by dealers and prohibitions on municipal securities business and to extend the rule to cover municipal advisors. You can view our final comment letter here. Specifically, our comments focused…
BDA Submits Comment Letter to the SEC in Response to MSRB's Proposed Rule Change on Best Execution of Transactions in Municipal Securities
Today, the BDA submitted a comment letter to the SEC in response to a request for comment regarding MSRB’s proposed rule change on best execution of transactions in municipal securities. You can view our final comment letter here. Specifically, the letter addresses the following: The approach taken by the MSRB is flawed on a technical level since…
BDA Submits Comment Letter to MSRB on Post-Trade Transparency and a New CTP
Today, the BDA submitted a comment letter to the MSRB in response to a request for comment regarding dissemination of post-trade transaction data and a New Central Transparency Platform. You can view our final comment letter here. Specifically, the letter addresses the following: Continued concern regarding the implications of reporting conditional trading commitments and the…
BDA Submits Comment Letter to the SEC: Proposed New Rule G-44, on Supervisory and Compliance Obligations of Municipal Advisors
The final letter focuses on: A Request for Minimum Standards for all Municipal Advisors; The Importance of Self-Certification; Outsourcing of the CCO Function; Concerns with the Implementation Date. You can view our final letter here. You can view the MSRB’s submission of the proposed new rule to the SEC in the Federal Register here and…
BDA Submits Comment Letter to the SEC: Proposed Amendments to MSRB Rule G-3 on Continuing Education Requirements
The final letter focuses on: Support for Increased Municipal Securities Training; Concerns with Additional Compliance Burden and Duplicative Requirements; Concerns with Enforcement of Continuing Education Requirements. You can find the final letter, as submitted, here. You can view the MSRB’s submission to the SEC in the Federal Register here and BDA’s previous letter to the…