Today, BDA and other associations sent a letter to the SEC Office of Municipal Securities on amending issuer continuing disclosure agreements (CDAs). “In the Adopting Release for the 1994 Amendments to Rule 15c2-12, the Securities and Exchange Commission (“SEC”) promoted flexibility in drafting CDAs required by the amended Rule while adhering to a basic framework,…
Category: Comment Letters
BDA and Others Submit Comments to the SEC on CDAs
“In the Adopting Release for the 1994 Amendments to Rule 15c2-12, the Securities and Exchange Commission (“SEC”) promoted flexibility in drafting CDAs required by the amended Rule while adhering to a basic framework, in line with the official statement for the particular offering. As a result, there is no uniform CDA used by all over the…
BDA Submits Comment Letter to the SEC on FINRA's TRACE Academic Data Set Proposed Rule
BDA submitted a comment letter to the SEC on FINRA’s rule proposal to create a new TRACE data set for institutions of higher education. BDA’s letter opposes the creation of the new data set because it would create unnecessary business risks for broker-dealers. BDA requests that FINRA re-propose the rule proposal and have dealers grouped anonymously…
BDA Submits Comment Letter to the SEC on FINRA's CMO Reporting and Dissemination Proposed Rule
Today, BDA submitted a comment letter to the SEC on FINRA’s rule proposal to require a new reporting and dissemination regime for CMOs. BDA’s letter expresses appreciation for the amendments that FINRA has proposed to its February 2015 request for comment. However, BDA argues that FINRA’s proposed $1 million threshold for real-time dissemination will create a bifurcated…
BDA Submits Letter to House Leadership in Defense of Muni Bond Tax Exemption
The BDA recently submitted a letter to House Speaker Paul Ryan (R-WI) and Rep. Kevin Brady (R-TX), Chairman of the House Ways & Means Committee, in response to the federal tax reform plan known in Washington as the “Blueprint”. This letter focuses on maintaining the current law status for tax exempt municipal bonds. You can…
BDA Submits Comment Letter to MSRB on Bank Loan Disclosure Concept Proposal
BDA Submits Comment Letter to MSRB on Bank Loan Disclosure Concept Proposal The BDA submitted a comment letter to the MSRB that responds to the MSRB’s request for comment on a concept proposal to require the municipal advisor (MA) involved in a direct purchase or placement of a bank loan to disclose that direct purchase or bank loan…
BDA Submits Comment Letter to MSRB on Proposed Amendments to Rule G-15(f) on Minimum Denominations
On May 25, 2016, BDA submitted a comment letter to the MSRB on proposed amendments to Rule G-15(f) on minimum denominations. You can view a copy of the letter here. The MSRB’s proposed rule amends MSRB Rule G-15(f) to provide exceptions related to prohibitions which restrict municipal securities dealers from effecting transactions with customers below…
BDA Submits Comment Letter to the SEC: FINRA Rule 4210 "TBA" Margin Amendments
On May 2nd, BDA submitted a comment letter to the SEC in response to FINRA’s filing of Amendment #2 on its Rule 4210 “TBA” margin amendments. The SEC solicited public comment on Amendment #2 and designated a longer period for Commission action for assessing the proposed rule. The Commission has until June 16, 2016, the maximum allowable timeframe for the…
BDA Submits Letter to MSRB on Rule G-12, Modernizing Close-Out Procedures
The BDA submitted a comment letter to the MSRB on the proposed amendments to Rule G-12, to modernize close-out procedures. You can view BDA’s letter here. The proposed amendments to MSRB Rule G-12 would require open inter-dealer transactions in municipal securities to be closed-out. Currently, there is no MSRB rule that requires a transaction to be closed-out.…
BDA Submits Letter to SEC: MSRB Rule A-3, Lengthening the Term of Board Member Service
Yesterday, the BDA submitted a comment letter to the SEC on MSRB’s proposed rule to lengthen the term of board member service. You can view the letter here. BDA’s letter focused on the following issues: Support for the MSRB’s proposal to lengthen terms for their board members to provide greater board continuity and overall effectiveness Urging the…