BDA Submits Comment Letter to MSRB Regarding Guidance on SMMPs

This proposal would streamline and codify existing guidance regarding the application of MSRB rules to transactions with SMMPs, currently set forth in interpretive guidance to MSRB Rule G-17.  The MSRB is proposing to establish a stand-alone definition for SMMPs and a single, comprehensive rule addressing dealers’ obligations to SMMPs.

You can find the BDA’s final letter [here.]

The letter included discussion on the following items:

  • Customer Affirmations Should Allow for Flexibility
  • The Asset Threshold Language Should be Consistent with FINRA’s Rule
  • Technical Corrections
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