by Sarah Wynn Potential changes to Financial Industry Regulatory Authority rules would likely reflect on the municipal space as the regulator contemplates lessons learned during the pandemic and dealers seek greater work-from-home flexibility. In comment letters filed Tuesday, dealer groups said FINRA should work with the Securities and Exchange Commission and Municipal Securities Rulemaking Board…
Category: FINRA & MSRB’s Retail Confirmation Markup Disclosure Rules
The BDA is advocating for one harmonized rule between the MSRB and FINRA that provides clear and valuable information to investors regarding markups on certain retail trades.
BDA Comments on Pandemic and Remote Work Issues
BDA today submitted comments to FINRA in response to FINRA Notice 20-42, “FINRA Seeks Comment on Lessons From the COVID-19 Pandemic.” FINRA requested comment on how firms have managed through the pandemic and what actions FINRA should take going forward. The letter can be viewed here. BDA told FINRA “Firms have generally reported that after the market disruption…
MSRB releases guidance on Rule G-23 and the SEC’s Temporary Conditional Order
The MSRB this afternoon released guidance addressing the interaction of MSRB Rule G-23 and the SEC’s Temporary Conditional Order related to the role of Municipal Advisors in bank placement transactions. The guidance is in the form of an addition to the MSRB’s COVID-related frequently asked questions. As you may recall, BDA reported last Friday that the MSRB…
BDA to MSRB: Its Time to Address Dramatic Funding Imbalances and Outdated Revenue Model
Today, the Bond Buyer featured a BDA op-ed titled, Its Time to Address the Dramatic Funding Imbalances and Fix MSRB’s Revenue Model. The piece comes as the 10th anniversary of the Dodd-Frank Act approaches next month, and following the recent submission of MSRB Draft Amendments to Rule A-3 and A-6. The Op-Ed can be viewed…
MSRB Not Expected to Pursue Pre-Trade Transparency Rulemaking
Last week, the MSRB held its quarterly Board Meeting, covering a broad range of topics, including Pre-Trade Analysis. The Board discussed staff’s analysis of pre-trade data voluntarily provided by ATS’s which notes a significant increase in the amount of responses to RFQ’s and live quotes between 2015 and 2018. The BDA spoke with the MSRB…
FINRA Files for 4210 Effective Date Extension to March 2021
FINRA has filed with the SEC a proposed rule change to extend (to March 25, 2021) the implementation date of the amendments to FINRA Rule 4210 (margin requirements). This delay, as well as certain changes to the amendments, are in line with BDA’s advocacy efforts and we appreciate all BDA members who helped drive those…
BDA Presses for Revision / Possible Repeal of MSRB Rule G23
Bond Buyer Op-Ed 5/16/2019 Time for a fresh look at Rule G-23 – Benefiting municipal issuers, taxpayers The Municipal Securities Rulemaking Board earlier this year announced that as part of its ongoing retrospective rule review, they are examining MSRB Rule G-23, “Activities of Financial Advisors.” The purpose of the initiative is “to ensure MSRB rules…
BDA Comment Letter: Draft Interpretation of Application of MSRB Rules to Certain Prearranged Trading
After consultation with various members and committees, the BDA has submitted a comment letter in response to the MSRB request for comment on draft interpretive guidance concerning the application of MSRB rules and prior interpretive guidance to certain prearranged trading in connection with primary offerings of municipal securities. The comment letter can be viewed here. The BDA…
BDA Submits Comment Letter: MSRB Draft Amendments to Primary Offering Rules
The BDA submitted a comment letter in response to the MSRB Request for Comment on Draft Amendments to Primary Offering Rules. The notice can be viewed here. The final comment letter can be viewed here. The comment letter focuses on the following topics: G-11 Primary Offering Practies Free-to-Trade Wire; and Alignment of the time frame…
Retail Confirmation Markup Disclosure Rules
Background: The MSRB and FINRA amended rules G-15, G-30 and FINRA Rule 2232 to require dealers to disclose the compensation received on certain municipal and corporate debt transactions. These disclosures must appear on confirmations sent to retail clients, based on the security’s prevailing market price. The rules were approved by the SEC in November 2016…