Letters

NASD Free-Riding and Withholding Interpretation

Summary

PSA The Bond Market Association (TBMA) provides comments to the National Association of Securities Dealers Regulation, Inc. (NASDR) on the NASDR’s proposal to exempt investment grade rated debt offerings from the scope of the NASD Free-Riding and Withholding Interpretation (IM-2110-1), NASDR Request for Comment 97-30.  PSA TBMA strongly supports the exemption and offers additional observations relating to the proposal.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.

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