DD Support Board and Research Team

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Here's what the Bond Dealers [BDA] wanted on August 6

"II. Exemptive Relief Sought

Based on the above, we respectfully request that the Commission issue an exemptive order excluding quotations published for fixed income securities from the scope of Rule 15c2-11.

We request that any security that is a debt security and any non-convertible preferred stock, collectively referred to herein as “fixed income securities” be included within the scope of the exemption. If the Commission is unwilling to exempt all fixed income securities, we request that the Commission delay implementation of Rule 15c2-11 until such time that a cost-benefit analysis for the application of Rule 15c2-11 to fixed income securities is completed and published for comment as part of the standard rule amendment process, to determine whether a specific subset of fixed income securities can be identified as suitable for coverage by the rule. Currently, it is already clear that the application of Rule 15c2-11 to large portions, if not all, of the fixed income market would be unnecessary, inefficient, and ineffective due to the nature of the securities, the method of offering the securities, the market for the securities, the disclosure regime applicable to the securities, or the nature of the transaction involving the securities. Without attempting to describe every instance, we note obvious examples such as (i) exempted securities including Treasury or GSE securities, (ii) securities already subject to mandatory disclosure requirements, and (iii) securities that are sold to qualified institutional buyers under Rule 144A.

SIFMA and BDA are willing and open to continued discussions with the Commission about the application of Rule 15c2-11 to the fixed income market.

Regards,"

https://d31hzlhk6di2h5.cloudfront.net/20210806/c6/7e/ac/c3/75dc2aa4fcbb0ddad02e571a/SIFMA-BDA_Draft_Exemption_Request_15c2-11_2021-08-06__003__ActiveUS_189303560__ActiveUS_1_.DOCX.pdf