Category: Comment Letters

BDA today filed a comment letter with the MSRB on their proposal to amend Rules G-47 and D-15. BDA did not oppose the G-47 changes and we supported the D-15 proposed amendments. Rule G-47 is the MSRB’s time of trade disclosure rule. It requires dealers to obtain and provide to customers certain material information about an issue…

BDA today filed a comment letter with the SEC in opposition to their proposed Regulation Best Execution. In the letter we ask the SEC to abandon the initiative because it is unnecessary, overly restrictive, and needlessly expensive. If the SEC moves forward with the proposal, we asked that it be amended to make it more…

BDA today filed a comment letter with FINRA in opposition to their proposal to amend TRACE trade reporting rules for delayed Treasury spot trades, secondary corporate bond trades where the spread to Treasuries is established early in the day but where the Treasury spot takes place later in the day at an agreed upon time. Under current…

BDA today provided comments to the MSRB on its proposal to amend MSRB Rule G-32 related to information reporting for municipal new issues. BDA generally supports the proposal. The MSRB has proposed to amend Rule G-32 to streamline the submission of new issue data on Form G-32. Under the proposal, underwriters would be required to submit certain…

We are pleased to inform you that the SEC announced yesterday that they have approved FINRA’s proposal to shorten the syndicate settlement time for corporate bond underwritings. This approval successfully culminates three years of BDA advocacy around this issue. The FINRA change approved by the SEC yesterday amends FINRA Rule 11880, Settlement of Syndicate Accounts. The Rule currently…

In a column published in today’s Bond Buyer and in a group letter to congressional leaders, BDA opposed a proposal pending in Congress to require municipal issuers to file financial disclosure documents such as annual financial statements in “machine-readable” format. BDA said “implementation of a machine-readable standard for municipal disclosures would be full of problems” and would…

BDA today filed comments with the MSRB and FINRA on their coordinated proposals to reduce the time dealers have to report trades to the MSRB’s Real-time Trade Reporting System (RTRS) and FINRA’s Trade Reporting and Compliance Engine (TRACE) from 15 minutes to one minute (MSRB proposal and FINRA proposal). We told the agencies “BDA strongly opposes the…

BDA today filed comments with the SEC supporting FINRA’s proposal to amend their Rule 11880 to shorten the time bookrunning managers of corporate bond underwritings have to pay out revenue to syndicate members. Under the proposal, bookrunners would be required to pay out 70 percent of gross syndicate revenue to comanagers no later than 30 days after…

BDA today filed comments with the SEC on a MSRB proposal to establish a new fee rate setting process for dealers and municipal advisors. In our letter we oppose the MSRB’s proposal and request that the SEC reject the initiative. The proposal would establish a new process for setting MSRB fees for regulated entites. Rather than fixed…

FINRA today announced that at their Board of Governors meeting last week, the Board approved a proposal to amend FINRA Rule 11880 to shorten the time to settle syndicate accounts. Although today’s announcement is not specific as to the terms of the amendment, we have been informed unofficially by FINRA staff that their Board approved…