Specifically, the BDA asked the SEC to suspend the implementation of the new rule because the assessment is unduly burdensome for broker-dealers and would affect middle-market dealers disproportionately. Additionally, we asked that the MSRB perform a calculation as to how much money they anticipate collecting from the $300 assessment for municipal advisor professionals so that…
Category: Comment Letters
BDA Submits Comment Letter on MSRB Draft Amendments to Rule G-3
Specifically, the letter addresses the following: • All municipal finance professionals should have the same training; • BDA suggested alternatives to the MSRB’s approach so as to alleviate some of our anticipated concerns; • The rule, as proposed, would be prohibitively costly to the industry; and • A suggested delay in implementation. You can find…
BDA Submits Comment Letter on MSRB Draft Rule G-44
Specifically, our letter addressed the following: We asked that the MSRB supply minimum standards for municipal advisors of all sizes; We asked that the MSRB make clear within the language of Draft Rule G-44 that the firm itself remain ultimately responsible for any decisions made or affected by the CCO, whether this position is outsourced…
FINRA TBA Margining Comments Filed
Today BDA filed comments, available [here], on FINRA Notice 14-02, “Proposed Amendments to FINRA Rule 4210” regarding TBA margining. Among other items, the comments assert that, in order to appropriately balance the essential liquidity provided by middle market dealers with its desire to address systemic risk: FINRA should consider exempting MBS specified pools, ARM and CMO markets from…
The Bond Buyer: Municipal Advisors Seek Changes, Clarifications on MSRB's MA Rule
by Kyle Glazier WASHINGTON — The Municipal Securities Rulemaking Board’s proposed standards of conduct for municipal advisors would unnecessarily prevent banks from providing normal banking services as well as muni advice, the American Bankers Association is warning. The ABA raised the concerns in one of more than 12 comment letters filed prior to Monday’s deadline…
BDA Members Meet with MSRB & SEC: Discuss SEC's Muni Advisor Rule and MSRB's Regulatory Regime for Municipal Advisors
Meeting with the MSRB BDA members primarily discussed concerns with MSRB proposed Rule G-42 on duties of non-solicitor municipal advisors. Specifically, we discussed the following items: Principal Transactions – We expressed our concern that the language contained in proposed Rule G-42 creates a potentially unworkable paradigm, which may cause an underwriter to be precluded from certain…
The Bond Buyer Commentary: Time of Trade Disclosure: Why a New Rule, Why the Delay?
The objective of the rule is simple: protect the retail investor. And when it comes to the municipal market, the rule already exists. So why is Proposed Rule G-47 pending approval by the Securities and Exchange Commission, and how will it differ from the existing rule? Why is this well-intentioned and, as some believe, needed…
FINRA Requests Comment on Proposed Amendments to FINRA Rule 4210 for Transactions in the TBA Market
The proposal addresses, among other things, maintenance margin and variation margin requirements, risk limit determinations, concentrated exposures, and exemptions for de minimis transfer amounts and for transactions cleared through registered clearing agencies. You can find the full Regulatory Notice here and the proposed rule amendment available here. A summary of the proposed amendments follows: The proposed…
BDA Submits Comment Letter to MSRB Re: Continuing Education Program
The comment letter focused on the following: Support for Increased Municipal Securities Education; Competency and Continuing Education Standards for Municipal Securities Activities Should be Collaborative and Consistent; Evidence of Compliance with Minimum Firm Element Continuing Education Requirements and Support for Harmonization with FINRA Rule 1032(b). You can view the full comment letter here.
BDA Submits Comment Letter: IRS Proposed Regulations Affecting Issue Price
Today the BDA submitted a comment letter to the IRS regarding proposed regulations affecting issue price. Highlights of the letter include discussion of the following: The rules must take into account the reality that municipal securities are bought and sold within the context of a fluid marketplace with capital at risk; The IRS must identify…