Today, BDA submitted a comment letter to the MSRB on proposed amendments to Rule G-15(f) on minimum denominations. You can view a copy of the letter here.
The MSRB’s proposed rule amends MSRB Rule G-15(f) to provide exceptions related to prohibitions which restrict municipal securities dealers from effecting transactions with customers below the minimum denominations specified in bond documents.
More specifically, the letter addresses:
- BDA’s general support for improving liquidity with certain securities below the minimum denomination
- Request for the MSRB to permit sales to customers of any amount below minimum denomination if the customer already owns a position at, or above, the minimum
- Request for the MSRB to permit the rescinding of inadvertent sales of below minimum-denomination positions as a safe harbor
- Request for the MSRB to consider permitting incremental additions to below minimum positions in certain situations
Additional information:
You can view the MSRB’s regulatory notice here.
We hope this information is helpful.
Jessica Giroux at jgiroux@bdamerica.org
John Vahey at jvahey@bdamerica.org
Justin Underwood at junderwood@bdamerica.org