In response to the SEC’s request for comment, BDA submitted the following comment letter. BDA’s letter focuses on the following issues: The legal and compliance cost burdens for middle-market dealers to implement and continue to maintain the requirements of this proposed rule The fact that the proposed margin amendments will not have a fair and equitable impact…
Category: Comment Letters
BDA Submits Letter to SEC on MSRB Pay-to-Play Rule
BDA submitted a comment letter to the SEC on MSRB’s proposed pay-to-play rule. You can view the letter here. More specifically, the letter addresses: BDA’s support of extending MSRB’s rule to cover MAs; BDA’s request for additional guidance on regulatory filings for dealers; and, BDA’s request to raise the de minimis threshold from $250 to $350…
BDA Submits Comment Letter to SEC in Response to FINRA ATS Trade Reporting Amendments
BDA submitted a comment letter to the SEC on SR-FINRA-2015-055, a Notice of Filing and Immediate Effectiveness of a Proposed Rule Change to Provide FINRA with Authority to Grant Exemptions from TRACE Reporting for Certain ATS Transactions. Please review BDA’s comment letter to the SEC here. The proposed rule creates a process for ATSs to be exempt from…
BDA's January 2016 Member Fly-in Focused on FINRA 4210 Margin Amendments
On Thursday January 7th, as part of BDA’s member fly-in initiative, BDA member firms and BDA staff met with the SEC, FINRA, and senior staff at the Senate Banking Committee and the House Financial Services Committee to discuss the proposed TBA, CMO, and specified pool margin amendments to Rule 4210 that FINRA filed with the SEC.…
BOND DEALERS OF AMERICA 2015 YEAR-IN-REVIEW – REGULATORY & LEGISLATIVE ADVOCACY
BOND DEALERS OF AMERICA 2015 YEAR IN REVIEW FEDERAL REGULATORY & LEGISLATIVE ADVOCACY In early 2015, BDA Board Chair Steve Genyk of Janney Montgomery Scott discussed the BDA’s 2015 municipal market priorities in an interview with the Bond Buyer. Genyk discussed maintaining the tax-exemption for municipal bonds and increasing the annual issuance limit for issuers…
BDA 2015 Year in Review-2
Bond Dealers of America 2015 Year in Review Federal Regulatory & Legislative Advocacy 2015 REGULATORY INITIATIVES During this period of massive regulatory change, BDA is focused on the highest priority regulatory issues impacting the U.S. fixed income markets and provides members with valuable opportunities to engage directly with regulators. Bond Buyer Interview with BDA Chair…
BDA Submits Comment Letter to FINRA and MSRB on Proposed Retail Markup Disclosure and Pricing Reference Rules
Today, BDA submitted a comment letter in response to the MSRB/FINRA proposed retail confirmation disclosure rules. BDA will continue to advocate for a simpler, less confusing, and less costly solution on this high-priority issue, including scheduling in-person meetings with all the relevant regulators in the near future. We will keep BDA membership informed on next steps…
BDA Submits Comment Letter to MSRB Regarding Proposed Amendments to Shorten the Settlement Cycle
The BDA’s comment letter focused on concerns regarding the potential impact a T+2 settlement cycle would have on middle market securities dealers. Specifically, we address the following: BDA believes the proposed rule will make clearing and settling transactions more efficient, reducing risk in the marketplace, but concerns remain with regard to the implementation aspect of…
Issue Price: BDA Submits Additional Comment Letter to the IRS and U.S. Treasury
Today, BDA submitted an additional comment letter to the IRS and Treasury as a follow up to our October 7 meeting with IRS and Treasury officials and our testimony at the IRS public hearing. The purpose of the letter is to provide answers to the following questions, which were asked by regulators during our meeting and the public…
BDA Submits Comment Letter Regarding FINRA Proposal Relating to Financial Exploitation of Seniors and Other Vulnerable Adults
Our comment letter focuses on the following: Request for further clarification of the proposed rule and additional guidance Concern with verification and reliance on information collected by member firms Seeks further guidance regarding information provided to the trusted contact person Concern with language related to changes in status for the trusted contact person and requests…