BDA Requests Exemption from SEC Rule 15c2-11

BDA today sent a draft letter to SEC staff requesting exemptive relief with respect to SEC Rule 15c2-11, “Publication or submission of quotations without specified information ” as a prelude to a meeting to discuss the BDA requests. The BDA intends to ask the SEC to exempt fixed income products from the Rule. The Rule currently does…

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…

BDA Submits Comment Letter: SEC Rule 15c2-12

BDA submitted a comment letter to the SEC regarding its request for comment on SEC Rule 15c2-12. The BDA’s letter is accessible here. The Commission solicited comments on the regulatory burden for underwriters and issuers associated with Rule 15c2-12 compliance. In addition, SEC requests comments on “ways to enhance the quality, utility, and clarity” of information collected…