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WASHINGTON, DC – The American Securities Association (ASA), along with the Bond Dealers of America (BDA), the National Association of Municipal Advisors (NAMA), and the Securities Industry and Financial Markets Association (SIFMA), submitted a comment letter to the U.S. Securities and Exchange Commission (SEC) regarding the Municipal Securities Rulemaking Board’s (MSRB) Proposed Rule to establish 2024 Rate Card Fees.
“ASA is advocating for heightened transparency in the MSRB’s budgeting process by urging the future inclusion of detailed information on expenditures and more formal and informal interactions with stakeholders to ensure affected market participants are more involved in the sustainability and fairness of the MSRB's financial practices,” said ASA General Counsel & Head of Fixed Income Policy Jessica Giroux.
The letter noted the lack of transparency in the MSRB’s budget and its budgeting process, and the need for MSRB's resources to be directed toward areas within its statutory authority.
“The MSRB's budgeting and rate-setting strategy is alarmingly opaque and troubling, particularly as it entails formulating spending plans before securing revenues to meet these financial targets. Our interest in this area is great, since MSRB budget increases lead to underwriter and municipal advisor fee increases. Similar to our collective and individual comments from the previous year, there continues to be a lack of detail in the MSRB's budget, particularly in instances where expenses are not directly tied to projects aligned with its congressional mandate. Without this information it is difficult for regulated entities and the SEC to assess whether the fees assessed are “reasonable” as required in Section 15B(b)(3)(B),” the organizations wrote in the letter.
The letter further expands on these views and can be found here.
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About the American Securities Association
American Securities Association, based in Washington, DC, represents the retail and institutional capital markets interests of regional financial services firms who provide Main Street businesses with access to capital and advise hardworking Americans how to create and preserve wealth. ASA’s mission is to promote trust and confidence among investors, facilitate capital formation, and support efficient and competitively balanced capital markets. This mission advances financial independence, stimulates job creation, and increases prosperity. The ASA has a geographically diverse membership of almost one hundred members that spans the Heartland, Southwest, Southeast, Atlantic, and Pacific Northwest regions of the United States.