*Letters

Prevailing Market Prices and Mark-Ups for Transactions in Municipal Securities

Published on:
June 7, 2010
Committee:

SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) responding to a draft interpretive guidance on prevailing market prices and mark-ups for transactions in municipal securities issued by the MSRB, MSRB Notice 2010-10. SIFMA requests that the MSRB (1) allow for a more flexible approach in determining prevailing market price; (2) permit a more flexible approach to documenting transactions; (3) expand the exemption from the guidance to include all transactions by dealers with a SMMP; (4) expand the discussion of the situations in which a bond dealer may consider itself a market maker; and (5) provide dealers with more guidance regarding the definition of “contemporaneous cost”.

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