Category: Comment Letters
BDA Supports Proposed Changes to MSRB Rule G-10
Yesterday, BDA submitted a comment letter to the MSRB on Notice 2021-08, “Request for Comment on Amendments to Rule G-10 Notification Requirements for Dealers.” MSRB last month issued the Notice and proposed to amend MSRB Rule G-10. Rule G-10 requires municipal dealers to send certain annual information disclosures to investor customers and issuer clients. View the…
BDA Comments on FINRA Margin Proposal for Agency MBS
BDA today filed a comment letter with the SEC in regard to their consideration of a FINRA proposal to amend FINRA Rule 4210, Margin Requirements, as it applies to Covered Agency Transactions (CATs), or agency MBS trades that settle outside a T+2 window. In our letter, we told the SEC that we are “seriously concerned…
BDA Comments on Electronic Trading
The BDA today submitted comments to the SEC on their “Concept Release on Electronic Corporate Bond and Municipal Securities Market.” We focused our comments just on Section VIII of the release related to electronic trading in corporate and municipal bonds. The concept release was motivated by a recommendation from the SEC’s Fixed Income Market Structure…
BDA Comments on Pandemic and Remote Work Issues
BDA today submitted comments to FINRA in response to FINRA Notice 20-42, “FINRA Seeks Comment on Lessons From the COVID-19 Pandemic.” FINRA requested comment on how firms have managed through the pandemic and what actions FINRA should take going forward. The letter can be viewed here. BDA told FINRA “Firms have generally reported that after the market disruption…
BDA Sends Comments to SEC on Proposed Changes to MSRB Rules A-3 and A-6 on Board Composition and Governance
BDA this morning filed a comment letter with the SEC on proposed changes to MSRB Rules A-3 and A-6 on board composition and governance. The proposal before the SEC is available here. BDA’s comment letter is available here. Senator Kennedy’s MSRB reform bill is available here. he proposed changes will, when approved by the SEC, impose these changes: Reduce…
BDA Submits Comments in Support of FIMSAC Rule 17a-7 Proposal
Following the June 1st FIMSAC meeting, the BDA submitted comments to the SEC in support of the Committees proposal titled, Preliminary Recommendation Regarding Modernizing Rule 17a-7 under the 1940 Act. The BDA believes the proposal would provide significant benefits for investors in certain fixed bond mutual funds without any threat to safety, or fair pricing, however…
BDA Urges Congress to Support Muni Provisions in Potential Stimulus Package
As Congress begins deliberating a potential “stimulus 4“ legislative package, the BDAtoday submitted comments to both House and Senate leadership, calling for support of state and local governments through direct funding, and pressed for support of the municipal market by enacting: The reinstatement of advance refundings; Raising the BQ debt limit; and A direct pay…
BDA Submits Comments on Draft Amendments to MSRB Rule A-3: Membership on the Board
Today, following extensive work with BDA membership committees and leadership, the BDA submitted comments in response to the MSRB request for comment on Draft Amendments to Rule A-3. The comment letter can be viewed here. The BDA comments, among other points, requests that the MSRB consider: A five-year separation requirement for independent directors is too…
BDA Submits Additional Comments to Fed on Municipal Liquidity Facility
Today, following continued discussions with the Muni Exec Committee, the BDAsubmitted comments to the Federal Reserve in response to the announcement of the Municipal Liquidity Facility. The BDA comments follow prior communications with the Federal Reserve and Treasury, and focus on support of the new program, while providing additional recommendations for the Fed as they…