Bond Dealers of America (BDA) deploys a variety of advocacy, educational, informational and grassroots tools to influence the policy-making process and promote a more efficient market. Regulatory authorities in Washington recognize us as an authority on technical issues and market trends. Through a variety of events and forums, our members have the opportunity to meet regulators, policymakers and legislators to discuss market and business challenges. Our federal Political Action Committee supports legislators who work to advance policies that improve the fixed income markets.
Municipal Advisor Regulatory Regime
To facilitate conversations about the Municipal Advisor (MA) rule, BDA produced a market document available to members, that summarizes how the MA Regulatory Regime impacts issuers and borrowers in the municipal securities market.
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.
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.
IRS Proposed Regulations on Issue Price
BDA has engaged the IRS and Treasury in discussions about the market impact of the IRS’s re-proposed rule, submitting multiple comment letters, testifying at a public hearing and meeting directly with IRS and Treasury staff.
The DOL’s rule applies a fiduciary duty to those providing investment advice to retirement investors. BDA advocated in comment letters and in testimony, for common sense changes to the rule and for the DOL and the SEC to coordinate their efforts. The SEC has stated it intends to publish a proposed rule applicable to the standards of care provided by broker-dealers and investment advisers at a later date.
Best Execution Standards for Municipal Securities
Best execution requires the use of “reasonable diligence” to identify the best trading venue for customer transactions under prevailing market conditions. BDA has produced a considerations document to assist member firms in updating policies and procedures according to MSRB guidance.
The BDA continues to urge the Fed, OCC, and FDIC to work jointly on a rule that includes all investment grade municipal securities, including investment grade revenue bonds.
Private Placement Activity of Non-Dealer Municipal Advisors
BDA is concerned that non-dealer municipal advisors (MAs) may be violating securities law in certain instances by acting as unregistered dealers in private placements. We encourage the SEC and MSRB to remind MAs that acting as a placement agent is a broker-dealer activity with associated legal requirements.
Protecting Tax-Exempt Municipal Bonds
BDA works with industry partners, including issuers and state and local groups, through the Municipal Bonds for America (MBFA) Coalition to preserve the tax exempt status of municipal bonds.
Bank Qualified Bonds
BDA supports legislation to permanently increase the bank qualified annual debt limit from $10 million to $30 million, index that amount for inflation, and apply it to individual borrowers.