The BDA’s comment letter focused on concerns regarding the potential impact a T+2 settlement cycle would have on middle market securities dealers.
Specifically, we address the following:
- BDA believes the proposed rule will make clearing and settling transactions more efficient, reducing risk in the marketplace, but concerns remain with regard to the implementation aspect of the Proposed Amendments
- Transactions occurring in the secondary market for municipal securities should follow the proposed T+2 settlement cycle as opposed to a “blanket” requirement for all transactions, including those for new issue markets
- We caution that the impact of shortening the settlement cycle will filter through other regulations tied to the settlement date of a municipal security, potentially resulting in new regulatory burdens for dealers
You can find our final letter here.
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