The proposed guidance would subject underwriters to after-the-fact second guessing by regulators on matters such as the price of the bonds, disclosures to issuers, and retail orders. The BDA’s comments are available here.
Category: Comment Letters
BDA Comments on FINRA Markup and Markdown Proposals
The BDA believes that this Regulatory Notice does not adequately address the realities of the debt securities market. The BDA believes that the proposal exacerbates the current uncertainty, does not reflect the market realities when firms trade on a principal basis, especially when they are market-makers, and as a result favors and encourages agency trading…
BDA Comments on Proposed Changes to Rule G-23
The BDA urged the SEC to delay the implementation of changes to Rule G-23 until the new fiduciary duty of municipal advisors is more clearly delineated, because that may eliminate the need for any changes to Rule G-23. If changes to G-23 do move forward, the BDA urged the SEC to allow financial advisors to…
BDA Sends Comment Letter to SEC Study Regarding Obligations of Brokers, Dealers, and Investment Advisers
View Letter Here
Auction Rate Securities
Read Comment Letter Here
ARS Reporting Proposal at MSRB
Download Comment Letter