BDA Comment Letter on the Presidential Memo on the Fiduciary Duty Rule Today, the BDA submitted a comment letter that is focused on the questions raised by President Trump’s February 3rd memorandum. Comment Letter Summary In response to the issues raised in the Presidential Memo, the BDA’s comment letter states that the rule will unnecessarily restrict access to fixed-income…
Category: Comment Letters
BDA Submits Comment Letter: Amendments to MSRB G-34 on CUSIPs
BDA submitted a comment letter, available here, in response to MSRB’s request for comment on draft amendments and clarifications to Rule G-34 on obtaining CUSIP numbers. The draft letter focuses on the following: The Draft Amendments will not permit issuers to issue and investors to purchase privately placed municipal securities without CUSIP numbers even though there are good…
BDA Comment Letter to DOL on Proposed 60-Day Delay to Applicability Date of the Fiduciary Duty Rule
The Department of Labor proposed a 60-day delay to the applicability date of the fiduciary duty rule. Comments on the 60-day delay were due by Friday, March 17th. The BDA comment letter is here. BDA Comment Letter Summary BDA expresses support for the 60-day delay and recommends a longer, 180-day delay BDA notes that the Labor Department’s economic cost-benefit…
BDA to Submit Petition for SEC Rulemaking: Amendments to Form ADV
Today, BDA will submit a letter that petitions the SEC to engage in a rulemaking to amend Form ADV. BDA’s recommendations, if adopted, would make client prospecting more efficient for dealer sales personnel. BDA’s Recommended Changes: BDA’s letter recommends three changes to Form ADV: Recommendation 1: Harmonize the client and client-related asset under management percentages in Item 5, section…
BDA Submits Comment Letter to the SEC on its Proposed Amendment to Shorten the Settlement Cycle to T+2
Today, BDA submitted its comment letter to the SEC on its request for comment on a proposed amendment to Rule 15c6-1(a) to shorten the settlement cycle from T+3 to T+2 and is designed to reduce systemic risk for U.S. market participants. You can view the BDA’s letter here. BDA’s Letter: Requests that the SEC work with…
BDA Submits Comment Letter to MSRB on Request for Comment on Proposal to Clarify Minimum Denomination Rule
BDA submitted a comment letter in response to MSRB’s request for comment on draft MSRB Rule G-49 on minimum denominations. BDA Letter Summary: The letter states that the proposed MSRB Rule G-49 should be focused on issuances with ‘minimum authorized denominations’ of $100,000 and above Additionally, the letter argues that dealers should have increased flexibility to…
BDA Submits Comment Letter on FINRA Gifts, Gratuities and Non-Cash Compensation Rules
BDA submitted its comment letter to FINRA in response to its request for comment on proposed amendments to its gifts, gratuities, and non-cash compensation rules. You can view FINRA’s regulatory notice here. FINRA has proposed to consolidate various interpretative guidance documents related to gifts and non-cash compensation into the FINRA rulebook. Additionally, FINRA is proposing to increase…
BDA Submits Comment Letter to the SEC on FINRA’s Retail Confirmation Rule
Today, BDA submitted a comment letter to the SEC in response to FINRA’s proposed retail confirmation disclosure rule. BDA’s letter focuses on: The urgent need for FINRA and MSRB to harmonize their rules from a policy, testing date, and effective date standpoint BDA urges regulators to appreciate the operational burdens associates with automating the process for making…
BDA Submits Comment Letter to the SEC on FINRA's U.S. Treasury Transaction Reporting Proposed Rule
BDA submitted a comment letter to the SEC on FINRA’s proposed rule to require reporting of U.S. Treasury security transactions to TRACE. BDA’s comment letter expresses general support for the proposal. However, BDA urges regulators to not implement fees or pursue public dissemination of Treasury transaction information in the future. In addition, BDA urges FINRA…
BDA Submits Letter to the SEC on MSRB's RTRS Academic Data Set Proposal
Today, the BDA submitted its letter to the SEC on MSRB’s proposed rule to establish a new data set of RTRS transaction data exclusively for institutions of higher education. The comment period expires on August 10, 2016. You can view the BDA’s letter here. BDA’s letter opposes the creation of the new data set as…