On Monday, BDA sent a follow-up letter, available here, to Chair White and copied all SEC Commissioners as well as the Commission’s Enforcement Division. In our letter, we reiterated our request for an extension of the initiative until December 15, 2014, and set fourth two arguments, specifically:
- The inadequate NIRMSIRs system is providing an unnecessarily complicated search; and
- The disproportionate cost to small and mid sized firms is unduly burdensome.
We are also in receipt of a letter from LeeAnn Ghazil Gaunt, Unit Head, Municipal Securities and Public Pensions Unit, Division of Enforcement at the Commission, in which she addresses receipt of and acknowledges the concerns we had laid out to Chair White in our original letter, here. The intent of our follow-up letter is to reinforce the need for modifications to the initiative and to request an in-person meeting with Chair White or her staff.
Additionally, the BDA has been in touch with numerous staff at various interested trade groups in DC about the MCDC Initiative to find out what they are hearing, the approach their members are taking and to help guide us on our next steps.
We are working with member firms to produce a guidance document to help member firms enhance your disclosure procedures going forward.
Press relating to BDA’s initiatives on MCDC:
- The Bond Buyer published a story regarding BDA’s letter which can be found here.
