BDA today filed a comment letter with the SEC in regard to their consideration of a FINRA proposal to amend FINRA Rule 4210, Margin Requirements, as it applies to Covered Agency Transactions (CATs), or agency MBS trades that settle outside a T+2 window. In our letter, we told the SEC that we are “seriously concerned…
Category: FINRA Mortgage Security Margin Amendments
FINRA amendments to Rule 4210 require a new margining regime for mortgage products, including TBA securities. BDA continues to work with our members to assist in establishing appropriate compliance regimes for middle-market dealers so that they can continue to provide liquidity to the TBA market.
BDA Files Letter on FINRA Margin Rule
Continuing to provide lead advocacy, BDA today filed a comment letter on a FINRA proposal to amend FINRA Rule 4210 to apply to trades in when-issued securities with long delivery times. The changes generally specify that firms must collect margin for customers for trades in securities with settlement times longer than standard. Alternatively, firms can take capital…
FINRA Requests Comment on Rule 4210 – Follows BDA Member Recommendations
Today, following extensive work with the BDA and its members, FINRA announced that they seek to comment on proposed amendments to Rule 4210 (Margin Requirements) that would clarify and incorporate into the rule current interpretations regarding when issued and other extended settlement transactions, and provide relief to facilitate the application of the rule to these…
BDA Draft Letter to FINRA on Corporate Syndicate Settlement Period
Please see attached a draft letter from the BDA to FINRA, asking FINRA consider amendments to Uniform Practice Code Rule 11880, to reduce the period to settle corporate syndicate accounts from 90 days to a shorter time period. BACKGROUND: FINRA Uniform Practice Code Rule 11880 stipulates that corporate underwriting syndicates must be settled no later…
UPDATE: FINRA Board Approves Revisions to 4210 Amendments
During FINRA’s September Board Meeting, the FINRA Board of Governors approved revisions to the Covered Agency Transaction margin requirements that would: (1) Eliminate the 2-percent maintenance margin requirement; (2) Allow firms to take a capital charge in lieu of collecting margin for mark to market losses, subject to specified limitations and conditions; and (3) Streamline the…
Rule 4210 Update: BDA Submits Capital Charge Letter to FINRA
On June 7, 2018, the BDA continued leading the advocacy push opposing FINRA Rule 4210 by submitting a letter in support of a “Capital Charge” provision in lieu of the proposed margin requirements. The letter, which comes on the heels of a 9 month delay of implementation of the rule by the SEC last month,…
BDA FINRA Rule 4210 Letter: Competitive Concerns, Compliance Questions, and a Proposed Amendment for FINRA’s Consideration
August 8, 2017, BDA submitted a letter to FINRA to respond to its request for interpretive and compliance questions related to the FINRA 4210 margin regime for mortgage securities. BDA FINRA 4210 Letter Summary First Good Settlement Date: The letter re-submits BDA’s proposed amendment to the rule, which would re-define “Covered Agency Transaction” to exclude TBA, CMO, and…
BDA Submits Comment Letter to the SEC on MSRB Customer Complaint and Record Keeping Rule Amendments
BDA Submits Comment Letter to the SEC on MSRB Customer Complaint and Record Keeping Rule Amendments On December 9, 2016, BDA submitted a comment letter to the SEC on the proposed amendments that the MSRB filed to MSRB Rules G-8, G-9, G-10, and G-32 with the SEC. BDA Letter Summary: BDA argues that MSRB should have published…
BDA Submits Comment Letter to the SEC: FINRA Rule 4210 "TBA" Margin Amendments
On May 2nd, BDA submitted a comment letter to the SEC in response to FINRA’s filing of Amendment #2 on its Rule 4210 “TBA” margin amendments. The SEC solicited public comment on Amendment #2 and designated a longer period for Commission action for assessing the proposed rule. The Commission has until June 16, 2016, the maximum allowable timeframe for the…
BDA Submits Comment Letter to the SEC on FINRA 4210 Margin Amendments
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…