BDA’s letter generally supports the MSRB’s proposal but also asks the MSRB to consider implementing a training program during year one of service with the expectation that board members will be municipal market experts by year four thereby maximizing the benefits of the proposed fourth year of service. You can find our final letter here.
Category: Comment Letters
Michael Imhoff of Stifel, Nicolaus & Co. Testifies at IRS Public Hearing on 'Issue Price' for Municipal Securities
Today, Michael Imhoff, Managing Director of Fixed Income Capital Markets at Stifel, Nicolaus & Co. testified on behalf of the BDA at an IRS public hearing on the recently proposed rule to define ‘issue price’ for municipal securities. BDA’s public hearing testimony can be read here. The following people also testified at the public hearing:…
BDA Submits Letter to SEC on FINRA Rule 4210 TBA Amendments
BDA has submitted its comment letter to SEC on FINRA Rule 4210, to establish margin requirements for the TBA Market. The BDA’s letter can be read here. BDA’s comment letter highlights that the burden of this rule will fall on small-to-medium sized dealers transacting with medium-to-large sized counterparties and focuses on the following areas of…
BDA Submits Issue Price Comment Letter to IRS
Today, BDA submitted a comment letter to IRS in response to its request for comment on a proposed rule to re-define ‘issue price’. The proposal partially withdraws the 2013 issue price proposal. The BDA’s draft letter focuses on: Problems for issuers and the marketplace that will be caused by an actual sales approach and the absence of a…
BDA Sumbits Letter to SEC on TRACE 'No Remuneration' Indicator
BDA submitted a letter to the SEC in response to a request for comment on a proposal to require a ‘No Remuneration’ indicator for TRACE trade reports when trade prices do not include a commission or markup, markdown. This SEC-filed proposal would harmonize TRACE reporting with the previously approved amendments to G-14 for municipal securities trade reporting. The…
BDA Submits Comment Letters to FINRA and MSRB on Market Data Sets
BDA submitted the two letters in response to two requests for comment by FINRA and one request for comment by the MSRB. Both FINRA and MSRB requested comment on a new academic data set that would include a dealer-specific identifier. The second, FINRA specific, request for comment is a proposal to reduce the delay associated…
BDA Testifies Before U.S. Department of Labor on Fiduciary Duty
In his remarks, Nicholas focused on how the proposed expansion would significantly limit the ability of dealers to provide investment advice and recommendations to retirement investors. You can find his prepared remarks here. Specifically, Nicholas spoke about how the BDA does not believe the proposed rule or the associated exemptions represent the right approach for improving…
BDA Submits Comment Letter to SEC on Proposed Amendments to FINRA Rule 6730 to Require Members to Report Transactions in TRACE-eligible Securities 'As Soon As Practicable'
Today, BDA submitted a comment letter to the Securities and Exchange Commission on a proposal to codify in FINRA Rule 6730 that members are expected to report transactions in TRACE eligible securities that are subject to dissemination “as soon as practicable” (but not later than 15 minutes of the time of execution or other timeframe…
BDA Submits Comment Letter to Federal Reserve on Municipal Securities as ‘High Quality Liquid Assets’ (HQLA)
Today, BDA submitted a comment letter to the Federal Reserve in response to its proposed rule to allow investment grade, general obligation U.S. state and municipal bonds to be counted as High Quality Liquid Assets (HQLA) under the Liquidity Coverage Ratio (LCR), a new bank liquidity rule. The proposed rule would include GO municipal securities as…
BDA Submits Comment Letter to Labor Department on Fiduciary Duty Proposal
Today, BDA submitted a comment letter to the Labor Department (DOL) regarding its request for comment on a proposal to expand the definition of ‘fiduciary’ under Employee Retirement Income Security Act (ERISA). As proposed, the expansion would significantly limit the ability of dealers to provide investment advice and recommendations to retirement investors. BDA’s letter focuses on…