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Michael Imhoff of Stifel, Nicolaus & Co. Testifies at IRS Public Hearing on 'Issue Price' for Municipal Securities

Today, Michael Imhoff, Managing Director of Fixed Income Capital Markets at Stifel, Nicolaus & Co. testified on behalf of the BDA at an IRS public hearing on the recently proposed rule to define ‘issue price’ for municipal securities.


BDA’s public hearing testimony can be read here.


The following people also testified at the public hearing:

  • Nancy Winkler, City Treasurer, City of Philadelphia on behalf of GFOA
  • Linda Schaklel, Partner, Ballard Spahr Public Finance on behalf of NABL
  • Michael Decker, Co-head of Municipal Securities, SIFMA on behalf of SIFMA


Summary of BDA’s Testimony:

  • BDA’s testimony focused on the issues with the proposed general rule, which would require 10% of each maturity to be sold to the public in order to establish issue price.
  • BDA has recommended an actual sales standard that would be based on 50% of an entire issuance being sold to the public, an approach that was supported by the testimony of GFOA at the hearing.
  • A second recommendation BDA’s testimony focused on is for IRS and Treasury to develop a safe harbor for┬ácompetitive┬ádeals and BDA has pledged to work with regulators to craft a workable safe harbor.
  • BDA also discussed the complexities of complying with the proposed alternative rule, which would likely cause underwriters to price bonds with higher rates in order to meet the actual sales requirements of the general rule in order to avoid the alternative rule.


BDA’s issue price comment letter can be read here.

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