Today, the BDA submitted a letter to the Federal Reserve in support of the recent creation of the Secondary Market Corporate Credit Facility (SMCCF). In the letter, the BDA states its belief that the SMCCF has the potential to help the corporate bond market return to normal conditions quickly as the corporate bond market is not…
Category: Comment Letters
Fed Announces Municipal Liquidity Facility
Announcement Follows BDA Letter / Recommendations to the Fed The Federal Reserve today announced the guidelines of the Municipal Liquidity Facility, authority that was provided by the recent passage of the CARES Act. The fact sheet can be viewed here. Last week, the BDA urged to the Fed and Treasury to take action in the primary…
BDA Responds with Narrowly Tailored Parameters to Any Potential Exemptive Relief for Municipal Advisors
After multiple meetings at the SEC including with the Chair, all Commissioners, and staff leadership at the Office of Municipal Securities and Trading and Markets, today (1/28/20) the BDA submitted comments to the SEC that would narrowly tailor the proposed exemptive order. Following extensive work with the BDA working group and outside counsel Davis Polk…
BDA Delivers Strong Message to SEC: Reject the Exemptive Order Outright
Both the BDA and C-Suite Leaders Submit Comments with the SEC Today, following extensive work with the BDA working group, BDA policy committees, and outside counsel Nixon Peabody and Davis Polk, the BDA submitted two letters in opposition to the SEC request for comment . The BDA comments, which can be viewed here, argue that the Commission…
BDA Draft Letter to FINRA on Corporate Syndicate Settlement Period
Please see attached a draft letter from the BDA to FINRA, asking FINRA consider amendments to Uniform Practice Code Rule 11880, to reduce the period to settle corporate syndicate accounts from 90 days to a shorter time period. BACKGROUND: FINRA Uniform Practice Code Rule 11880 stipulates that corporate underwriting syndicates must be settled no later…
BDA Continues to Lead Industry Pushback on the PFM and NAMA Requests to Avoid Broker-Dealer Regulation
Since learning of the October 2018 request from advisory firm PFM in late spring, the BDA has lead industry efforts to push back against the initial request and subsequent efforts from NAMA. Below, is a recap of all BDA advocacy activity, including meeting recaps and an overview of the 3 letters submitted to the SEC.…
BDA Urges SEC to Reject the PFM and NAMA Requests to Avoid Broker-Dealer Regulation
After much consultation with the BDA Municipal Division and Legal and Compliance Committee leadership, along with BDA outside counsel-Nixon Peabody and Davis Polk, the BDA has submitted a letter to the SEC strongly opposing the recent requests for guidance regarding private placement activity by non-dealer municipal advisors. The BDA learned late last week that the SEC is…
BDA Releases a GSE Reform “White Paper” as the Debate on a Housing Finance Overhaul Heats Up
In the coming weeks, Treasury Secretary Steven Mnuchin, Housing and Urban Development Secretary Ben Carson and Federal Housing Finance Agency Director Mark Calabria are all scheduled to testify before Congress regarding the Trump Administration’s plan to reform Fannie Mae and Freddie Mac. The administration’s blueprint document on a reform plan is likely to be released…
BDA’s Letter on the Anticipated Joint Agency Proposal to the Community Reinvestment Act (CRA)
Recently, FDIC Chair Jelena McWilliams announced that bank regulators will release a joint draft proposal for reform measures to the Community Reinvestment Act (CRA). The regulators are expected to release a formal proposal on or around August/September 2019. The BDA has identified an issue related to certain community development activities concerning investments in loan-backed securities that…
BDA Submits Comment Letter on TRACE pilot/corporate bond block trade dissemination
Thank you to those who participated in BDA’s calls regarding FINRA’s proposal (Notice 19-12) to implement a pilot program to test changes in TRACE dissemination rules on corporate bond market liquidity. The final BDA comment letter is available here. Summary of BDA’s comment letter: BDA opposes the pilot program proposal. The proposed 48-hour delay in…