A Summary of BDA’s Comment Letter to the MSRB Include:
- Draw distinctions between the municipal and corporate bond markets and urge the MSRB not to simply cut and paste from FINRA Rule 5310;
- Recommend that any rule provide for policies and procedures to be put in place rather than being applied on a trade-by-trade basis;
- Advise that a best execution rule may be workable for bonds that dealers purchase for their customers, but that for bonds that they sell, best execution through multiple venues is unworkable as the market is often illiquid and in those cases, the MSRB should look to the current fair pricing rule regime.
- Recommend that SMMPs be excluded from the protection of the rule.
You can view the final comment letter [here.]