A Summary of BDA’s Comment Letter to the MSRB Include: Draw distinctions between the municipal and corporate bond markets and urge the MSRB not to simply cut and paste from FINRA Rule 5310; Recommend that any rule provide for policies and procedures to be put in place rather than being applied on a trade-by-trade basis;…
Category: Comment Letters
BDA Submits Comment Letter to MSRB Re: Concept Release on a New Central Transparency Platform
The comment letter focused on the following items: Keeping certain end of day reporting exceptions intact for list offering transactions and RTRS takedown transactions Warned that the dissemination of too many new data elements may confuse the investor Cautioned against the potential to undermine trading strategies Re-iterated a previous concern that shortening the 15 minute…
BDA Chair Brad Winges Interviewed by the Bond Buyer on BDA Muni Market Priorities
By Kyle Glazier The Bond Dealers of America will issue a report on municipal bankruptcy in the wake of Detroit’s filing last month, and will also release a best execution proposal for the municipal market, the group’s leaders recently said. BDA president and chief executive officer Mike Nicholas and board chairman Brad Winges talked about…
BDA Submits Comment Letter to SEC on MSRB Retail Order Period Proposal
This letter closely follows the letter BDA submitted to the MSRB in November 2012 [here], but expands upon some arguments which were addressed by the MSRB in the Federal Register notice which you can view [here.] You can read the final letter to the SEC [here.]
BDA Submits Comment Letter to MSRB Regarding Guidance on SMMPs
This proposal would streamline and codify existing guidance regarding the application of MSRB rules to transactions with SMMPs, currently set forth in interpretive guidance to MSRB Rule G-17. The MSRB is proposing to establish a stand-alone definition for SMMPs and a single, comprehensive rule addressing dealers’ obligations to SMMPs. You can find the BDA’s final…
BDA Submits Comment Letter Re: MSRB Revisions to Suitability Rule
The final letter focused on the following items: MSRB Should More Clearly Identify What Constitutes a Hold Recommendation Proposed Rule G-19 Should Include an Exception for an SMMP Similar to FINRA’s Exception for Institutional Investor Accounts under FINRA Suitability Rule 2111 Supplementary Material for Proposed Rule G-19 Should be Updated View the full letter [here.]
BDA Submits Comment to FINRA on Proposed Rules Governing Markups, Commissions and Fees
BDA’s comment letter focused on the following: Definition of prevailing market price Maintaining QIB exception Lack of Objective Enforcement Standards in determining a markup Spreads for distressed bonds are higher than for non-distressed bonds You can view the full comment letter [here.] View BDA’s letter on the initial markup proposal [here.]
BDA Submits Comment Letter on MSRB Fiscal Year 2014 Annual Planning
The BDA believes MSRB’s priorities for fiscal year 2014 should be as follows: Enhance the User Capabilities of EMMA Advance Municipal Advisor Regulation Focus on Cost-Benefit Analysis in Rulemaking Further Clarification of MSRB Rule G-17 Disclosure Requirements MSRB Rule Language Should be More Objective You can view our full letter [here.]
BDA Submits Statement to House Committee on Ways and Means: Focuses on Importance of Tax-Exempt Municipal Bonds
BDA’s testimony focuses on the vital importance of maintaining the tax exempt status of municipal bonds and the potential impact on the municipal market, investors, and issuers if the tax exemption for municipal bonds is altered, replaced or eliminated. View the full statement [here.]
BDA In the News: Small Dealers Oppose Faster Trade Reporting Requirements
View the full Bond Buyer article [here.] View BDA’s comment letter on MSRB’s proposed new Central Transparency Platform [here.]