BDA Comment Letter Summary
- BDA believes the best solution to help facilitate the timely flow of commentary to investment managers would be a clear interpretation of “research report” that demonstrates that the vast majority of desk commentary is not fundamental research
- If and when FINRA proposes rule text for the safe harbor, it should provide clarity on desk commentary content
Recent BDA Actions
- BDA Comment Letter: On July 14th, BDA submitted a comment letter in response to FINRA’s request for comment on a proposed safe harbor for desk commentary. The letter is here.
- Morgan Lewis Memo: In May, Amy Natterson Kroll of Morgan Lewis joined BDA’s conference call to discuss the proposed safe harbor. A memo on the proposal authored by Ms. Kroll can be read here.
- FINRA Proposal: FINRA has requested comment on a proposed safe harbor from the debt research rule specifically for desk commentary distributed to certain institutional customers.
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