The MSRB has requested that the SEC approve the proposed interim assessment for effectiveness on October 1, 2011. Comments on the assessment should be submitted to the SEC. The MSRB expects the interim assessment to remain in effect for a limited period of time during which the MSRB will decide whether to make the interim…
Author: Bond Dealers of America
BDA Update
BDA’s July 18, 2011 Washington Advocacy Update is available here.
BDA supports Rep. Garrett's bill for SEC cost benefit analysis.
The SEC Regulatory Accountability Act would require the SEC to conduct cost benefit analysis on proposed regulations. A copy of the bill is available here. The BDA support letter is available here.
BDA Opposes SEC Substitute for Credit Ratings
The substitute proposed by the SEC would require firms to set up their own systems for evaluating credit-worthiness, essentially reproducing the system of the credit ratings agencies. This approach would be extremely detrimental to smaller firms, to issuers and to investors. Because it is based on an inherent conflict of interest, the proposed system would…
Rep. Garrett (R-NJ) Introduces SEC Accountability Bill
The legislation will require the SEC to perform a cost-benefit analysis of any new rulemaking to ensure the benefits outweigh any costs to stakeholders, including doing a comparison of the cost/benefit of not regulating at all. This legislation has just been introduced, and is a key step forward by an important member of the House…
SEC Delays Rule 15c3-5 for Fixed Income
The SEC announced last night that it will delay the compliance date for Rule 15c3-5 from July 14, 2011 until November 30, 2011 for fixed income securities. In addition to delaying all aspects of the Rule for fixed income securities, the SEC will also delay until November 30 the pre-trade credit and capital limit requirements of…
BDA Urges Level Playing Field for Muni Advisors
As part of its efforts to regulate municipal advisors under Dodd-Frank, the MSRB proposed a new Rule G-44, analogous to Rule G-27 that applies to broker-dealers, but with some differences that would regulate stand-alone municipal advisors less stringently. Many broker-dealers regulated under G-27 are also municipal advisors and thus the proposed rule would favor one…
BDA Newsletter – June 20, 2011
Information on those meetings and other happenings is available here.
BDA Opposes IRA Proposal to Reduce MRB Purchase Price Limits
The IRS proposed in Revenue Procedure 2011-23 to move to a new method of calculating the purchase price limits for Mortgage Revenue Bonds. Under long-standing practice, the purchase price limits are calculated based on FHA loan limits. The IRS proposed shifting the HUD county-level price data, which would significantly lower the purchase price limits. The…
BDA Releases Guidelines for Secondary Market Disclosure
These guidelines are in response to FINRA’s Notice 10-41 which included a “checklist.” A description of the guidelines is available here. An Executive Summary is available here.