*Letters

TBMA Submits Comments to the SEC on Rule 2320(a) Governing Best Execution

Published on:
April 5, 2005

The Bond Market Association (TBMA)* provides comments to the Securities and Exchange Commission (SEC) on proposedamendments to National Association of Securities Dealers, Inc.(NASD) Rule 2320(a) governing “Best Execution,” File No. SR-NASD-2004-026. The proposal would extend due diligence obligations to an NASD member firms own customers, and the customers of another broker-dealer. TBMA believes that because of the special characteristics of debt instruments and the structure of the fixed income market, rules crafted with other instruments in mind often cannot be imposed on the bond market without creating grave problems of interpretation, application and enforcement.

*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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