BDA Comments on FINRA Markup and Markdown Proposals

The BDA believes that this Regulatory Notice does not adequately address the realities of the debt securities market.  The BDA believes that the proposal exacerbates the current uncertainty, does not reflect the market realities when firms trade on a principal basis, especially when they are market-makers, and as a result favors and encourages agency trading as a business model, to the detriment of investors.  The BDA comment letter is available here.

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