BDA Submits Comment to FINRA on Proposed Rules Governing Markups, Commissions and Fees

BDA’s comment letter focused on the following:

• Definition of prevailing market price
• Maintaining QIB exception
• Lack of Objective Enforcement Standards in determining a markup
• Spreads for distressed bonds are higher than for non-distressed bonds

You can view the full comment letter [here.]

View BDA’s letter on the initial markup proposal [here.]