MSRB’s Request for Comment on Retrospective Review of Primary Offering Practices.

The MSRB has released for comment its concept proposal on MSRB rules on primary offering practices. The BDA’s letter suggests that existing MSRB rules adequately protect primary offering practices and the existing regulatory framework is sufficient, thus eliminating the need for new rules to govern primary offering practices. Public comments on the proposal are due Monday, November 13th.

BDA’s comment letter can be found here.

Draft Letter Summary:

Rule G-11 Primary Offering Practices

Rule G-32 Disclosures in Connection with Primary Offerings

Proposed Rule Summary:

MSRB’s request seeks insight on evolving primary offering practices and whether current rules continue to operate effectively or whether changes to MSRB Rule G-11, on primary offering practices, and Rule G-32, on disclosures in connection with primary offering practices.

Concerning Rule G-11 on Primary Offering Practices

Concerning Rule G-32 on Disclosures in Connection with Primary Offering Practices

Bond Dealers of America

November 17, 2017



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