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 two years, the proposal includes a 45-percent fee reduction for dealers in 2026 and 2027.
In our letter BDA told the SEC “BDA supports the Proposal and we encourage the Commission to approve it. While not without flaws, the Proposal is consistent with statute and generally represents a reasonable approach to a sustainable MSRB funding plan.” We also welcomed a planned MSRB review of municipal advisor business activity with an eye towards possibly implementing a market activity-based fee on MAs four years from now when fees are reset again. The proposal before the SEC includes a 6.6-percent increase in MA fees in 2026 and approximately 6-percent increases in each of the succeeding three years. Dealer fee rates will remain flat over the four-year period.
The MSRB last proposed fee rate changes in January 2024. The SEC effectively rejected that proposal, and 2023 fee rates have remained in effect since then.
BDA’s letter to the SEC is available here. Please call or write with any questions.