Category: Comment Letters

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…

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…

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…

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.

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…

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…

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…

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…

Revised draft rule G-42 incorporates a number of changes made by the MSRB to the rule text based upon comments received from the industry. Specifically, BDA’s letter focuses on: BDA’s support for the MSRB’s revised approach to principal transactions, with one further request for clarification; Review of recommendations and a request that the MSRB provide…