Today, the BDA submitted a comment letter to the MSRB registering concern for a Concept Proposal which would require public disclosure on EMMA of all payments, receipts or potential financial incentives made or received by dealers that may represent conflicts of interest. Although improved transparency is one of BDA’s most important policy priorities, we question…
Category: Comment Letters
BDA Submits Comment Letter to the MSRB on Elimination of Large Trade Size Masking on Price Transparency Reports
Today, the BDA submitted a comment letter to the MSRB on the elimination of large trade size masking on price transparency reports. BDA is pleased with the MSRB’s focus on transparency in the municipal markets and noted “We believe [in] the importance of increased transparency within the municipal markets and, more importantly, certainty that all…
BDA Submits Comment Letter to the SEC on FINRA Proposed Rule Change Relating to TRACE Reporting in Agency Specified Pool Securities
Today, the BDA submitted comments to the SEC on FINRA Proposed Rule Change Relating to TRACE Reporting and Dissemination of Transactions in Agency Pass-Through Mortgage-Backed Securities Traded in Specified Pool Transactions. In the letter, BDA expressed concern with the proposed rule and suggested an alternative solution. For the full comment letter, click [here.] The FINRA Notice…
BDA Submits Comments to the SEC ON MSRB Rule G-43, Broker's Brokers
Today, the BDA submitted to the SEC a comment letter on MSRB Notice of Filing of Proposed Rule G-43, on Broker’s Brokers; Proposed Amendments to Rule G-8, on Books and Records, Rule G-9, on Record Retention, and Rule G-18, on execution of Transactions; and a Proposed Interpretive Notice on the Duties of Dealers That Use the…
BDA Submits Comment Letter To The MSRB On Retail Order Periods
Today, the BDA submitted a letter to the MSRB outlining concerns with proposed rule amendments and interpretive Notice on Retail Order Periods. In part, the BDA stated, “We understand that the intent of the Notice is to curtail the failures of some Dealers to comply with the retail order period requriements of issuers and…
BDA Submits Comment Letter to MSRB on Proposed Changes to Rule G-34, Not Reoffered
Today, the BDA submitted a comment letter to the MSRB on proposed changes to Rule G-34, concerning the designation of “Not Reoffered” in connection with new issues of municipal securities. In the letter, BDA wrote, “By eliminating the “not reoffered” practice by some dealers, the Proposed Rule will allow other comparable transactions to have a…
BDA Submits Comment Letter on FINRA Proposal to Identify and Manage Conflicts in the Preparation and Distribution of Debt Research Reports
Comments include a concern that there is a failure justify a shift from the substance of the Guiding Principles to Promote the Integrity of Fixed Income Research (Guiding Principles) published by The Bond Market Association in 2004 – a document relied upon by dealers and investors alike, as the standard for governing fixed income research.…
BDA: It's Time to Implement Rules for Municipal Advisors
In an opinion piece featured in the Bond Buyer, BDA CEO Mike Nicholas writes, “More than one year after the enactment of the Dodd-Frank Act, and despite the work by the MSRB on writing a definition, virtually anyone can claim to be a municipal advisor, regardless of qualifications, political contributions or conflicts of interest. This…
BDA Submits Comments on MSRB Fiscal Year 2013 Priorities.
The MSRB announced earlier this year that it is seeking input as it develops its FY 2013 Priorities. The MSRB sought feedback from “market participants, other stakeholders and the general public to ensure that its planning activities include the broadest-possible array of input and information with which to establish regulatory and other priorities….The result of the…
SEC Approves GASB Support Fee.
The SEC approved FINRA’s proposal to impose a GASB support fee on broker-dealers in the municipal market. That proposal was finalized on February 23 and can be found here. The BDA submitted comments strongly objecting to continuing the practice of saddling broker-dealers with costs that should be imposed more broadly, or in some cases, not…