Proposed Agency Information Collection Activities; Comment Request (SIFMA and ISDA)
SIFMA and The International Swaps and Derivatives Association, Inc. (ISDA) provided comments to the Office of the Comptroller of the…
SIFMA provides comments to Municipal Securities Rulemaking Board (MSRB) on a draft interpretive notice concerning the application of MSRB Rule G-17 to underwriters of municipal securities, MSRB Notice 2011-12. Under Rule G-17, an underwriter is required to “deal fairly with all persons and shall not engage in any deceptive, dishonest, or unfair practice.” SIFMA believes that the MSRB should be careful not to transform the duty of fair dealing into a fiduciary-type obligation that imposes burdensome, expensive and unnecessary affirmative obligations by interpreting a prohibition on deception and fraud. Underwriters are not municipal advisors, and the standards applicable to each should be clearly distinguishable.
SIFMA and The International Swaps and Derivatives Association, Inc. (ISDA) provided comments to the Office of the Comptroller of the…
SIFMA AMG provided comments to the Federal Energy Regulatory Commission on the Federal Power Act Section 203 Blanket Authorizations for…
SIFMA, The Institute of International Bankers (IIB), and The International Swaps and Derivatives Association (ISDA) provided comments to the Commodity…
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