After consultation with various members and committees, the BDA has submitted a response to the recent the MSRB request for comment on MSRB Rule G-34 ,the “CUSIP Requirement”, which requires a municipal advisor advising an issuer with respect to a competitive sale of a new issue of municipal securities to apply for the assignment of a…
Category: Comment Letters
BDA Comment Letter: Draft Interpretation of Application of MSRB Rules to Certain Prearranged Trading
After consultation with various members and committees, the BDA has submitted a comment letter in response to the MSRB request for comment on draft interpretive guidance concerning the application of MSRB rules and prior interpretive guidance to certain prearranged trading in connection with primary offerings of municipal securities. The comment letter can be viewed here. The BDA…
BDA Submits Comment Letter on Draft Amendments to 2012 Interpretive Notice on the Application of Rule G-17 to Underwriters of Municipal Securities
After consultation with various Committees and members, the BDA drafted and submitted a comment letter on the MSRB’s request for public comment on draft amendments to the interpretive guidance it issued in 2012 on the application of MSRB Rule G-17 on conduct of municipal securities and municipal advisory activities, to underwriters of municipal securities. The comment letter…
BDA sends comment letter to MSRB on draft compliance under Rule G-40
October 17, 2018, the BDA submitted a comment letter to the MSRB on a draft compliance resource regarding application of content standards under Rule G-40. The final comment letter can be viewed here. The comment letter focuses on the following topics: The BDA believes that a number of the mock advertisement examples in the Notice are…
BDA Submits Comment Letter: MSRB Draft Amendments to Primary Offering Rules
The BDA submitted a comment letter in response to the MSRB Request for Comment on Draft Amendments to Primary Offering Rules. The notice can be viewed here. The final comment letter can be viewed here. The comment letter focuses on the following topics: G-11 Primary Offering Practies Free-to-Trade Wire; and Alignment of the time frame…
MSRB Requests Comment on Draft FAQs Related to the Use of Social Media under Advertising Rules
The MSRB is seeking public comment on a draft set of frequently asked questions (FAQs) related to the use of social media in advertising by municipal advisors and municipal securities dealers applicable under Rule G-21 and Rule G-40. The draft FAQs can be viewed here. In May, the SEC approved the MSRB’s proposed Rule G-40, on advertising…
BDA Submits Comment Letter on CFTC’s Proposed Amendments to the De Minimis Exception to the Swap Dealer Definition
Today, August 13, 2018, the BDA submitted a comment letter to the Commodities Futures Trading Commission (CFTC) in response to its request for comment on proposed amendments to the de minimis exception within the swap dealer definition. You can review a copy of the BDA’s draft letter here. BDA Comment Letter Summary–Primary Areas of Focus: The aggregate…
BDA Submits Comment Letter on MSRB Retrospective Review of Underwriter Disclosures to Issuers
Today, August 6, 2018, the BDA submitted a comment letter in response to the MSRB’s request for public comment on existing interpretive guidance on the application of MSRB Rule G-17. The letter can be viewed here. The comment letter requests that the 2012 Guidance: Should be modified to allow for the timing of some of the…
MSRB Requests Comment on Draft FAQs for Rule G-40
The MSRB is seeking comment on a draft set of frequently asked questions (FAQs) related to the application of Rule G-40, on advertising by municipal advisors, to the use of municipal advisory client lists and case studies by municipal advisors. Comments on the draft FAQs are due by July 27, 2018. The draft FAQs can…
BDA Sends Letters of Support for PCAOB Audit Exemption Bill Senate Banking Committee to Hold Hearing on the Bill Next Week
June 21, 2018, the BDA sent letters to the Senate Banking and House and Financial Services Committees requesting their support of The Small Business Audit Correction Act. The Senate letter can be viewed here and the House letter can viewed here. S. 3004 & H.R. 6021 would exempt privately held, small non-custodial brokers and dealers in good…