Today, the BDA submitted comments to the SEC in connection with FINRA’s proposed rule change to implement an accounting support fee to fund the Governmental Accounting Standards Board (the “FINRA proposal”). View BDA’s comments here.
Category: Comment Letters
BDA Submits Comment Letter to the SEC on MSRB Rule G-17.
Today, the BDA submitted a comment letter on G-17, underwriter disclosures to issuers. The BDA has previously provided comments on the Notice and we reiterate those comments, but also want to continue to encourage the SEC to finalize the definition of “municipal advisor” and regulate independent municipal advisors. See today’s comment letter here. For the…
Chairman Schapiro responds to Congressman Garrett's letter: addresses Investor Protection & Fiduciary Standard Initiatives.
On December 21, 2011, Congressman Scott Garrett, Chairman of the House Financial Services Subcommittee on Capital Markets and Government Sponsored Enterprises, sent a letter to SEC Chairman Mary Schapiro expressing disappointment in the “SEC staff’s recommendation to impose a uniform fiduciary duty on broker-dealers and investment advisors” as authorized under Section 913 of the Dodd-Frank…
BDA submits comments to the MSRB on Restated Sophisticated Municipal Market Professional Notice.
We believe that the regulation of the municipal market should be informed by and evolve with the market itself. To view the BDA’s full comment letter, click here.
BDA in the News: Volcker Rule May Adversely Impact Munis.
Clarity in the definition of market maker for fixed-income securities is important primarily because a clearer rule will encourage more dealers to take the risks associated with making a market and thus provide investors with greater liquidity. That greater liquidity will, in turn, foster a more efficient market and better allocation of resources. The BDA…
BDA IN THE NEWS: Critical of MSRB draft rule on broker's brokers.
MSRB Rule Could Hurt Liquidity. See Bond Buyer Article here (subscription required.) See BDA’s Comment Letter here.
BDA Objects to New Broker's Brokers Rules
The BDA objected to the reproposed rule because the proposed rule is unnecessary, because it would still require broker’s brokers to determine a fair price, which is not their role, because the proposed system of parameters is unworkable and because it would treat ATS the same as voice broker’s brokers, which they are not. The…
BDA IN THE NEWS: SEC Urged to Reject or Delay G-17 Fair-Dealing Guidance, The Bond Buyer
The Bond Buyer reports today: Market participants urged the Securities and Exchange Commission to reject or delay the Municipal Securities Rulemaking Board’s proposed interpretive guidance for Rule G-17 on fair dealing for underwriters, saying it would impose a fiduciary-like regimen of disclosure obligations that would only confuse issuers. View the article here (subscription required.) View BDA’s…
BDA Opposes SEC Substitute for Credit Ratings
The substitute proposed by the SEC would require firms to set up their own systems for evaluating credit-worthiness, essentially reproducing the system of the credit ratings agencies. This approach would be extremely detrimental to smaller firms, to issuers and to investors. Because it is based on an inherent conflict of interest, the proposed system would…
BDA Opposes IRA Proposal to Reduce MRB Purchase Price Limits
The IRS proposed in Revenue Procedure 2011-23 to move to a new method of calculating the purchase price limits for Mortgage Revenue Bonds. Under long-standing practice, the purchase price limits are calculated based on FHA loan limits. The IRS proposed shifting the HUD county-level price data, which would significantly lower the purchase price limits. The…