Category: Comment Letters

BDA in a letter yesterday to the SEC supported proposed changes to SEC Rule 15c2-11 to specify that the Rule applies only to equity securities. BDA told the SEC “The Commission has proposed to amend SEC Rule 15c2-11 to address the action taken by the previous Commission to apply the Rule to fixed income securities for the…

BDA today filed comments with the MSRB on their proposal to amend Rule G-27 related to supervision. BDA generally supported the proposal with additional suggestions. The MSRB has proposed to clarify the definition of “structuring of public offerings or private placements” for the purpose of Rule G-27 and has proposed to lengthen the time certain…

Yesterday, BDA sent a letter to the MSRB on the definition of Sophisticated Municipal Market Investor (SMMP) in MSRB Rule D-15. We supported a MSRB proposal to eliminate the need for SEC-registered Investment Advisers (IAs) to positively affirm their status as SMMPs and we opposed a proposal to raise the definitional threshold for state and…

BDA yesterday co-signed a letter to the SEC where we asked the Commission to exclude municipal securities from the definition of ABS under the SEC’s Regulation AB. The letter is in response to a SEC concept release that included an inquiry on amending the regulatory definition of ABS under Reg AB. The groups told the Commission “the…

BDA today filed with the SEC comments on the MSRB’s proposal to revise their Rate Card system for setting fees imposed on dealers and municipal advisors. The MSRB has proposed to implement a four-year fee schedule based on projected market activity over that time. Because the Board has collected too much revenue from dealers over the past…

The SEC yesterday approved rule changes by FINRA and the MSRB to withdraw last year’s amendments which would have required most TRACE and RTRS bond trades to be reported within one minute of execution. This final action reversing September’s approval of the trade reporting initiatives follows an extensive BDA advocacy campaign to refine and ultimately…

BDA today provided comments to FINRA in response to their review of regulations that affect “member workplaces.” FINRA states in their Notice “As part of the broad rule modernization review, this Notice seeks comment on how FINRA can further evolve its rules, guidance and processes to reflect modern business practices and markets; support innovation and new technologies;…

BDA today sent a letter to the SEC in support of proposals from FINRA and the MSRB to rescind the one-minute trade reporting amendments approved by the Commission last September. BDA told the Commission we “fully supports both Filings to revise and rescind the Amendments and we urge Commission approval. The one-minute reporting initiatives are unnecessary and would not…

BDA today filed with the SEC a letter in support of proposed amendments to FINRA’s “gifts rule.” We told FINRA “BDA supports FINRA’s proposal to raise the annual gift limit from $100 to $250. This increase is sensible and necessary, reflects decades of inflation, and aligns the rule more closely with actual business practices.” FINRA has proposed…

BDA today filed with FINRA a letter in response to FINRA Notice 25-04, “FINRA Launches Broad Review to Modernize Rules Regarding Member Firms and Associated Persons.” The Notice states that FINRA “is launching a broad review of its regulatory requirements applicable to member firms and associated persons.” The Notice also states “FINRA…requests comment on other areas…