Our letter retains our previously stated request that the SEC disapprove Proposed Rule G-42 as written since the amendment has not materially changed the Proposed Rule to make it workable for issuers and dealers.
Specifically, we address the following:
- We do not believe that Amendment No. 2 provides a meaningful and useful exception to the principal transaction ban because there are too many limitations for the exception to be useful
- The consent and disclosure requirements necessary to take advantage of the exemption to the transaction ban are entirely too burdensome to be useful
- We do not believe that dealers will use this exemption in any meaningful way unless the requirements are substantially reduced or unless the MSRB creates a more encompassing exemption from the principal transaction ban for brokerage services
You can find BDA’s letter here.
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