The DOL published a proposed rule to extend the transition period for the Department of Labor Fiduciary Duty Rule. The proposal would delay the applicability dates for the Best Interest Contract Exemption and the Principal Trading Exemption until July 1, 2019. BDA Comment Letter BDA submitted a comment letter on Friday, September 15th. The letter can be…
Category: Comment Letters
Regulatory Reform: BDA Submits Letter to U.S. Treasury Upcoming Report on U.S. Capital Markets and Securities Law & Regulation
On August 22nd, BDA submitted a letter to the Treasury Department regarding its upcoming report on U.S. Capital Markets Regulation, which is due out in the fall of 2017. The letter is here for your review. Treasury staff specifically requested BDA’s input on regulations, enforcement, and market liquidity. BDA’s letter focuses on the following issues:…
BDA Submitted Comment Letter: DOL Fiduciary Rule
On August 7, 2017, in response to a Request for Information published by the Department of Labor, the BDA submitted a comment letter to the DOL focused on how it should amend the Fiduciary Duty Rule and the Principal Trading and Best Interest Contract Exemption. BDA Comment Letter Summary — Primary Areas of Focus The Department of Labor and the…
BDA Submitted Comment Letter: Urges the Secretary of the Treasury to Withdraw the Proposed IRS Political Subdivision Rule
BDA Comment Letter: BDA Urges Withdrawal of IRS Political Subdivision Rule Please review the BDA’s comment letter, which urges the Secretary of the Treasury to recommend to the President, per the process required by Executive Order 13789 (outlined below), that the IRS proposed political subdivision rule be rescinded. BDA reiterates the arguments it made in previous…
BDA Submits Tax Policy Recommendations to Senate Finance Committee Chairman Hatch on Tax Reform
On July 17th, the BDA submitted its comment letter and policy recommendations in response to Senate Finance Chairman Orrin Hatch’s (R-UT) request for expert and stakeholder input on tax reform. You can view the BDA’s letter here. BDA’s Letter Recommends to: Do no harm to the current law status of the municipal tax-exemption Increase the…
BDA Submitted Comment Letter: DOL Exemption Applicability Date Delay
On July 21st, the BDA submitted a comment letter to the Department of Labor focused on whether the Department of Labor should delay the January 1, 2018 Best Interest Contract Exemption and Principal Trading Exemption applicability date. The letter is here. BDA’s letter expresses strong support for delaying the applicability date of the exemptions until the Department of…
BDA Submits Comment Letter: Proposed Limited Safe Harbor from FINRA Debt Research Rules for Desk Commentary
BDA Comment Letter Summary BDA believes the best solution to help facilitate the timely flow of commentary to investment managers would be a clear interpretation of “research report” that demonstrates that the vast majority of desk commentary is not fundamental research If and when FINRA proposes rule text for the safe harbor, it should provide…
BDA Submits Comment Letter: MSRB Second Request for Comment on Draft Amendments to and Clarifications of MSRB Rule G-34, on Obtaining CUSIP Numbers
The BDA submitted a comment letter to the MSRB in response to their second request for comment seeking industry input on draft rule amendments to MSRB Rule G-34, on CUSIP numbers, new issue, and market information requirements. You can find our final comment letter here. BDA’s comment letter addresses the following: Expresses support for the changes the…
BDA Submits Comments to Department of the Treasury and the Internal Revenue Service on Recommendations for the 2017-2018 Priority Guidance Plan
The BDA submitted comments to the Department of the Treasury and the Internal Revenue Service on recommendations for items that we believe should be included in their 2017-2018 Priority Guidance Plan. You can view our final comments here. The Treasury Department’s Office of Tax Policy and the IRS use the Priority Guidance Plan each year to…
BDA Submits Comment Letter: SEC Proposed Amendments to 15c2-12
On May 15, 2017, BDA submitted a comment letter in response to the SEC’s proposed amendments to Exchange Act Rule 15c2-12 which proposes to add two items to the list of event notices to be included in continuing disclosure undertakings. You can find our final letter HERE. Letter Overview: The BDA generally supports the concept of the Proposed…