The BDA has submitted written comments to the House House Ways and Means Tax Policy Subcommittee in support of fully reinstating tax-exempt advance refundings and expanding the use of private activity bonds (PABs). The comments can be viewed here. The comments were submitted in response to a recent hearing titled, “Tax Reform and Small Businesses: Growing Our Economy…
Category: Comment Letters
BDA Submits Written Comments in Support of Reinstating Municipal Advance Refundings and Expanding PABs
On May 7, 2018, the BDA submitted written comments to the Senate Finance Committee in support of fully reinstating tax-exempt advance refundings, including qualified 501c (3) bonds and expanding the use of private activity bonds (PABs). The comments can be viewed here. The comments were submitted in response to a hearing titled, “Early Impressions of the New Tax…
Update: BDA Sends Joint Letter with NAMA and SIFMA to SEC on MSRB’s Proposed Advertising Rule Change
On May 4, 2018, the BDA, along with the National Association of Municipal Advisors and the Securities Industry and Financial Markets Association, sent a letter to the SEC requesting that they disapprove proceedings with respect to the MSRB’s proposed amendments to Rule G-21 and new Rule G-40 until the MSRB further clarifies and addresses key issues…
BDA Submits Comment Letter: MSRB Seeks Input on a Compliance Resource to Help Distinguish Advice and Recommendations (Rule G-42)
The BDA has submitted a comment letter to the MSRB concerning municipal market participants and the public on a draft compliance resource about core requirements for municipal advisors related to providing advice on, and making recommendations of, municipal securities transactions or municipal financial products. The final comment letter can be viewed here. The letter states that…
BDA SUBMITS COMMENT LETTER: FINRA Requests Comment on the Application of Certain Rules to Government Securities and to Other Debt Securities More Broadly (Regulatory Notice 18-05)
On March 9, 2018, the BDA submitted a letter to FINRA in response to Regulatory Notice (18-05) requesting comment on the Application of Certain Rules to Government Securities and to Other Debt Securities More Broadly. You can view our final comment letter here. The comment letter outlines that: The BDA believes that the application of the…
BDA Submits Written Comments in Support of Reinstating Municipal Advance Refundings
On March 28, 2018, the BDA submitted written comments to the House Ways and Means Committee in support of H.R. 5003, that would fully reinstate tax-exempt advance refundings, including qualified 501c (3) bonds. A copy of the comments can be viewed here. The comments were submitted in response to a hearing titled,“Post Tax Reform Evaluation of Recently Expired Tax…
BDA Submits Comment Letter: MSRB Seeks to Establish Rule for Municipal Advisors and Update Dealer Standards on Advertising
On February 28, 2018, the BDA submitted a comment letter to the SEC in response to the MSRB’s proposed new rule, MSRB Rule G-40, on advertising by municipal advisors, and amendments to MSRB Rule G-21, on advertising by municipal securities dealers. You can view our final comment letter here. BDA’s comment letter focuses on the following topics: The BDA…
FINRA Proposes Changes to the Securities Industry Essentials Examination
To eliminate duplicative testing of general securities knowledge on the current representative-level qualification examination, FINRA has recently filed with the Securities and Exchange Commission a proposed rule change to restructure its representative-level qualification examination program. View the notice here. When the rule proposal is officially filed with the SEC and published in the Federal Register a 21-day…
MSRB’s Request for Comment on Retrospective Review of Primary Offering Practices
The MSRB has released for comment its concept proposal on MSRB rules on primary offering practices. The BDA’s letter suggests that existing MSRB rules adequately protect primary offering practices and the existing regulatory framework is sufficient, thus eliminating the need for new rules to govern primary offering practices. Public comments on the proposal are due…
2016-17 BDA’s Federal Regulatory and Legislative Priorities and Accomplishments
The following issue list highlights the BDA regulatory and legislative priorities over the past twelve months and the noted accomplishments achieved through direct Hill and regulator lobbying and by utilizing the BDA membership through meetings in Washington, DC and at BDA roundtables and conferences throughout the year. Thanks to your time and efforts, the BDA continues to expand our presence and impact and…