Today, BDA submitted an additional comment letter to the IRS and Treasury as a follow up to our October 7 meeting with IRS and Treasury officials and our testimony at the IRS public hearing.
The purpose of the letter is to provide answers to the following questions, which were asked by regulators during our meeting and the public hearing:
- How would you view a rule that would require an underwriter to hold the offering price at the initial offering price until such time that 10 percent of a maturity was sold to the public and the substantial amount standard was met?
- In the context of the alternative rule, how could the proposed rule’s requirement to document a bond sale at a price higher be clarified?
- How could one structure a potential safe harbor for competitive transactions that retains an actual-sales-to-the-public approach?
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