Category: Comment Letters

The letter states, in part, “As we have expressed in the past, one of the BDA’s most important policy priorities is to improve transparency within the municipal markets and we provide these comments from a platform of tremendous support for any measures that will improve market transparency but, in particular, technological improvements that will provide…

The BDA supports the incorporation of interpretive notices into rules as it serves to provide much desired clarity to market participants such as dealers, investors and regulatory examiners, however we outline some concerns. View the full letter [here.]

In its letter, the BDA outlined its concerns with the proposed regulation noting the purpose of client protection would not be served by the current rule as drafted. View the full letter [here.]

In its letter, the BDA outlines concerns with EMMA, MSRB Rules G-17, G-30 and others. The BDA also asks that MSRB rule language be more objective so that they are sufficient to provide guidance as to how such rules should be enforced. View the full letter [here.]

In the letter, BDA reiterated concerns regarding FINRA’s revised debt research proposal and offered suggestions for consideration. View the full letter [here.]

The BDA submitted a comment letter to FINRA in response to its request for comment on TRACE dissemination issues, Regulatory Notice 12-39. In the letter, the BDA said that raising dissemination caps provided very little additional protections to the retail investor but might, in fact, harm institutional investors. View the full letter [here.]

The BDA filed a comment letter in response to the MSRB’s revised draft rule amendments and a revised draft interpretive notice on Retail Order Periods.  In the letter, the BDA reiterated its support for the revised Notice, but remains concerned that as written, it will impose a costly, unreasonable and unnecessary burden on Dealers, stating “[t]here…

The BDA supports the MSRB’s focus on market transparency and we believe this is a significant step in evaluating improvements to overall municipal market transparency. However, as the MSRB suggested it would consider raising the threshold in the future “with a view towards bringing full transparency of exact par values to the municipal market in…

The requirement that the NRO or not reoffered designation not be used without also including the applicable price or yield information is an amendment to MSRB Rule G-34 on new issues and market information requirements. This new requirement, which becomes effective November 1, 2012, will apply to any written communication sent at or after the…

The BDA submitted a comment letter to the MSRB in response to a concept proposal relating to potential additional protections for individual investors effecting transactions through electronic brokerages when recommending municipal securities transactions to individual investors. In it’s letter, the BDA said that it supports the MSRB’s efforts to remind dealers that operate as electronic…